The tax provisions commonly referred to as “FATCA” use a 30% withholding tax to enforce a worldwide reporting regime designed to prevent U.S. persons from using offshore accounts to e...
Treasury has issued proposed regulations interpreting the segment of the Internal Revenue Code commonly referred to as “FATCA.” These proposed regulations would take a number of impor...
Section 871(m) of the Internal Revenue Code, enacted in 2010, imposes withholding tax on, among other things, “dividend equivalents” paid to foreign counterparties pursuant to “spec...
On July 22, the Tax Court published its decision in the case of Anschutz Company v. Commissioner, involving a taxpayer that (indirectly) engaged in various prepaid variable forward contra...
This report explores the history of the taxation of derivative gains and losses, in the hope of making some sense of where we are now, as well as some suggestions about improving the stat...
On March 18, President Obama signed the Hiring Incentives to Restore Employment Act (the “Act”). The Act includes a version of the “Foreign Account Tax Compliance Act,” a provisio...
Today, the IRS released guidance that provides significant relief to persons considering the extent to which they need to submit a Report of Foreign Bank and Financial Accounts (an “FBA...
The Treasury Department has released proposed regulations that would provide some relief to filers attempting to determine their obligations under the rules regarding the Report of Foreig...
On December 9, the House of Representatives will consider a bill to extend a variety of expiring tax provisions. As had been expected, the bill will include as revenue raisers a revised v...
A bill introduced yesterday by Senate Finance Committee Chairman Max Baucus (D.-Mont.) and others contains various proposals aimed at combating offshore tax evasion. The bill includes bot...
