News & Analysis as of

Grandfathered Obligations

A&O Shearman

Smoothing the Path for Financial Institutions on Brexit

A&O Shearman on

The U.K.’s HM Treasury has set out its approach to the grandfathering of EU27 businesses on Brexit and to how existing EU financial services directives and regulations are to be adopted into U.K. law at the moment of Brexit...more

Katten Muchin Rosenman LLP

DOL Issues (Some) Additional Guidance on the Fiduciary Investment Advice Rule and Best Interest Contract Exemption

The US Department of Labor (DOL) has issued its first set of FAQs under the fiduciary investment advice rule (the “Rule”) and related prohibited transaction exemptions. In general, the Rule provides that parties providing...more

Sheppard Mullin Richter & Hampton LLP

Legacy and Grandfathered Agreements are Not Subject to Disclosure Requirements Under the Department of Labor’s New “Persuader”...

On March 24, 2016, the U.S. Department of Labor’s (“USDOL”) Office of Labor-Management Standards (“OLMS”) published its highly controversial “persuader” regulation, which requires employers and labor relations consultants,...more

McDermott Will & Emery

Final Regulations on Affordable Care Act Market Reforms

McDermott Will & Emery on

Throughout 2010, the U.S. Departments of Health and Human Services, Labor and the Treasury (collectively, the Departments) issued interim final regulations (IFR) implementing ACA market reforms applicable to grandfathered...more

Morgan Lewis

Treasury, IRS Extend Certain FATCA Transitional Rules

Morgan Lewis on

IRS Notice postpones several key deadlines and provides other relief. On September 18, the US Internal Revenue Service (IRS) released Notice 2015-66 (the Notice) announcing that the US Department of the Treasury and the...more

Goulston & Storrs PC

IRS Will Extend Some FATCA Transition Rules

Goulston & Storrs PC on

In new Notice 2015-66 the IRS said it plans to amend FATCA regulations to reduce certain collateral restrictions on grandfathered obligations and extend the following transition rules: (1) the date for when withholding on...more

Morrison & Foerster LLP

IRS Delays FATCA Implementation

On July 12, 2013, the IRS released Notice 2013-43 (the “Notice”), which sets forth a revised timeline for the implementation of the Foreign Account Tax Compliance Act (“FATCA”). The most significant development is that...more

Saul Ewing LLP

The Employer’s Playbook for ACA Compliance: Ten Practical Strategies for 2014

Saul Ewing LLP on

The Affordable Care Act (a/k/a Health Care Reform, or the ACA) is complicated. While there is nothing in the ACA that requires any employer to provide group health care coverage to its employees, the failure to do so can come...more

Baker Donelson

Alabama Legislative Update – Week 10: Slow and Steady Movement by Senate and House

Baker Donelson on

As the Alabama Legislature moves closer to adjournment, legislation is making slow but steady progress. Tuesday and Thursday marked the 21st and 22nd days of the 2013 Regular Session. With only eight legislative days left and...more

Morgan Lewis

Revisions to FATCA Implementation

Morgan Lewis on

IRS announces certain new time lines for implementation and further interpretive guidance. On October 24, the Internal Revenue Service (IRS) announced several key revisions to Foreign Account Tax Compliance Act...more

Proskauer Rose LLP

IRS Announces Extended FATCA Deadlines

Proskauer Rose LLP on

On October 24, 2012, the U.S. Internal Revenue Service (IRS) issued Announcement 2012-42: Timelines for Due Diligence and Other Requirements Under FATCA (Announcement). The Announcement provides that final regulations (Final...more

Orrick, Herrington & Sutcliffe LLP

Proposed Treasury Regulations Implementing the Foreign Account Tax Compliance Act (“FATCA”)

On February 8, 2012, the Internal Revenue Service (“IRS”) announced the release of proposed regulations (the “Proposed Regulations”) for the next phase of implementing reporting and withholding provisions of the HIRE Act...more

Dechert LLP

Final Proposed FATCA Regulations Issued

Dechert LLP on

The U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) on February 8, 2012 issued proposed regulations addressing the implementation of the Foreign Account Tax Compliance Act (“FATCA,” which was...more

McDermott Will & Emery

Proposed Regulations Provide FATCA Compliance Guidance for Foreign Financial Institutions, Other Foreign Entities and U.S....

McDermott Will & Emery on

The U.S. Department of the Treasury and the Internal Revenue Service recently issued proposed regulations under Sections 1471–1474 of the Internal Revenue Code. The proposed regulations provide updated guidance on information...more

Proskauer Rose LLP

IRS and Treasury Department Publish Anticipated FATCA Guidance

Proskauer Rose LLP on

Proposed Regulations under the Foreign Account Tax Compliance Act Issued February 8, 2012 On February 8, 2012, the U.S. Treasury Department and the Internal Revenue Service ("IRS") released widely anticipated proposed...more

K&L Gates LLP

Why You Still Need to Care about FATCA

K&L Gates LLP on

In This Presentation: FATCA: Foreign Account Tax Compliance Act - History - Nuts and Bolts - Highlights of Proposed Regulations - Intergovernmental Agreement - Next Steps - Q&A Please see full...more

K&L Gates LLP

Next Phase of FATCA Guidance Arrives with Proposed Regulations and Announcement of Possible Intergovernmental Approach

K&L Gates LLP on

On February 8, 2012, the US Treasury Department (“US Treasury”) and the Internal Revenue Service (“IRS”) released long-awaited proposed regulations on the Foreign Account Tax Compliance Act (“FATCA”). The proposed regulations...more

Morgan Lewis

FATCA Proposed Regulations Unveiled by Treasury

Morgan Lewis on

On February 8, Treasury released nearly 400 pages of highly detailed proposed regulations (the Proposed Regulations) relating to the implementation of the Foreign Account Tax Compliance Act (FATCA). In drafting the Proposed...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Highlights of Proposed Regulations Issued Under FATCA and Multijurisdiction Plan for Information Sharing"

On February 8, 2012, Treasury and the IRS issued comprehensive proposed regulations (Proposed Regulations) that would, when finalized, implement the Foreign Account Tax Compliance Act (FATCA), which was enacted in March 2010....more

Baker Donelson

PPACA and Employers: New and Grandfathered Group Health Plans

Baker Donelson on

The Patient Protection and Affordable Care Act, as modified by the Reconciliation Act and Manager's Amendment imposes new responsibilities on employers of all sizes immediately and progressively through 2014. The majority of...more

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