News & Analysis as of

Internal Revenue Service Internal Revenue Code (IRC) Foreign Banks

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Troutman Pepper Locke

Section 899 Implications for Foreign Banks Lending to US Borrowers through US Lending Offices

Troutman Pepper Locke on

In an earlier alert, we described the potential impact of the One Big Beautiful Bill on withholding taxes imposed on loans made by foreign banks to U.S. borrowers. ...more

Cadwalader, Wickersham & Taft LLP

IRS Publishes Final Regulations on IBOR Transition for Published Rate Elections

On June 29, 2023, the IRS published final regulations that provide the appropriate reference rate to be used by a foreign bank that elects to use a published rate to determine the amount of excess interest expense allocable...more

Davies Ward Phillips & Vineberg LLP

Federal Courts Weigh in on the FBAR: Providing Relief from Outrageous Penalties

In this bulletin, we highlight two recent federal court cases in which U.S. taxpayers won major victories against the United States with respect to their obligations to report non-U.S. accounts on FinCEN Form 114 – Report of...more

McDermott Will & Emery

IRS Extends Implementation of Certain FATCA Provisions, Eliminates 2013 Reporting

On July 12, 2013, the Internal Revenue Service (IRS) issued Notice 2013-43, which extended the implementation of certain provisions of the Foreign Account Tax Compliance Act (FATCA) by six months and eliminated reporting on...more

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