On June 27, 2024, Switzerland and the United States executed the Agreement between Switzerland and the United States of America to Improve International Tax Compliance and to Implement FATCA (New IGA), which will take effect...more
Recently, President Biden signed a foreign military support bill (H.R. 815) into law, which also encompassed the 21st Century Peace Through Strength Act (the Act), a legislative proposal introduced in the House containing...more
It was about two years ago I recall writing an article on the QUAD, whose members are the U.S., India, Australia, Japan. It was truly a head scratcher to me as to just how India, Modi specifically, was able to navigate...more
The EU is harmonising the rules on the prudential supervision of EU branches of non-EU banks under CRD VI. The new EU-wide third country branch regime will introduce minimum requirements including capital and liquidity...more
The United States - Australia Climate, Critical Minerals and Clean Energy Transformation Compact (the “Compact”) is a landmark formal statement of strategic intent to establish climate, clean energy and a shared energy...more
The OECD breaks new ground with historic declaration on government access to private sector data: Why is the declaration important and how can it help enable data free flow with trust?...more
El 12/30/22, el IRS emitió el Aviso 2023-11 con el propósito de proporcionar alivio de informes FATCA a las FFI Modelo 1 que no han podido obtener los TINs (“Tax ID Numbers”) de los EE. UU. para sus cuentas preexistentes que...more
On 12/30/22, the IRS issued Notice 2023-11 with the purpose of providing FATCA reporting relief to Model 1 FFIs who have been unable to obtain US TINs for their pre-existing accounts that are US reportable accounts. In turn,...more
El intercambio automático y masivo entre el fisco de Estados Unidos y otros países empezó con la ley de cumplimiento fiscal de cuentas extranjeras (Foreign Account Tax Compliance Act o FATCA). FATCA es parte de una larga...more
The role of U.S. courts in international arbitration has fundamentally shifted. The Supreme Court issued a unanimous decision in ZF Automotive US v. Luxshare holding that 28 U.S.C. § 1782 does not apply to international...more
While the announcement is short on details, once in place, U.S.-based. entities will be able to use the new agreement to comply with the GDPR’s cross-border data transfer requirements. On March 25, the U.S. and E.U....more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 7, 2020 – September 11, 2020... September 4, 2020: The IRS published Competent...more
On December 13, 2018, proposed regulations (Proposed Regulations) were issued that reduce certain compliance obligations under Sections 1471-1474 (the Foreign Account Tax Compliance Act (FATCA)) of the Internal Revenue Code...more
On December 13, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) addressing various aspects of the withholding...more
• Foreign Investor Forms W-8: An update of Forms W-8 on file for non-U.S. investors is generally recommended by December 31, 2018 to ensure that a date of birth (DOB) and non-U.S. taxpayer identification number (Foreign TIN)...more
Immigration has, and continues to be, a major flashpoint between California and the Trump administration. In 2017, the California legislature passed significant legislation (AB 450) impacting how California employers deal...more
More than a half century ago, the World Health Assembly established the International Agency for Research on Cancer as the specialized cancer agency of the World Health Organization. Although headquartered in Lyon, France,...more
The Open-Ended Intergovernmental Working Group that is considering an international treaty on business and human rights held its third session from October 23-27 in Geneva. ...more
The Centers for Medicare and Medicaid Services (CMS), in an August 3, 2017 letter to Florida’s Medicaid Director, approved a five-year extension of the State’s 1115 demonstration project, the Managed Medical Assistance...more
The British Virgin Islands (“BVI”) is a small chain of islands in the Caribbean situated between Puerto Rico and St. Maarten. The BVI has been a top sailing destination since the days of Sir Francis Drake. The BVI is a...more
We have previously written about the Internal Revenue Service’s publication in late 2016 of an updated “FFI Agreement” to be entered into by foreign financial institutions that wish to remain compliant with the Foreign...more
FATCA is Chapter 4 of the Internal Revenue Code (IRC). It conscripts Foreign Financial Institutions (FFIs) to act as reporting and withholding agents for the U.S. Government. To enforce its conscription, it contains a...more
More than six years after the U.S. Supreme Court’s decision in Carcieri v. Salazar, Sen. John Barrasso (R-Wyoming), the chairman of the Senate Committee on Indian Affairs, has introduced the “Interior Improvement Act” to fix...more
Just one day after the October 15 deadline for filing personal income tax returns on extension, the Internal Revenue Service issued a strongly-worded warning to non-compliant taxpayers: take action now to fix your problem, or...more
The Luxembourg government has brought to Parliament a bill of law transposing UCITS V into Luxembourg’s UCI Law and AIFM Law. Further, the Luxembourg CSSF published a new version of its AIFMD Frequently Asked Questions, among...more