Searching Content indexed under Tax Authorities by James Barry ordered by Published Date Descending.
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Redemption Of Interest In US Partnership Not Taxable To Foreign Investor; Tax Court Refuses To Follow Revenue Ruling 91-32
In general, a non-US person is not subject to US federal income tax when he sells stock of a US corporation.
United States
31 Jul 2017
Proposed US Treasury Regulations Attempt to Distinguish "Active" Insurance Companies from Hedge Funds
Offshore insurance companies can provide substantial tax benefits to their owner-insureds through current deductions for the insurance premium and, if properly structured, deferral on reserve investments.
United States
28 Apr 2015
Recent Developments Concerning US Tax Code Section 871(m) Dividend Equivalent Withholding Rules
Two developments may be converging in a way that will result in delayed effective dates for US final dividend equivalent regulations.
United States
3 Feb 2015
IRS And Treasury Issue Long-Awaited Guidance On Corporate Inversions And "Disqualified Stock"
On January 16, 2014, the Internal Revenue Service (the "IRS") and the Treasury Department (the "Treasury") issued longawaited temporary and proposed regulations under Code section 78741 relating to corporate inversions (the "Regulations").
United States
30 Jan 2014
Announcement 2012-42: Timelines For Due Diligence And Other Requirements Under FATCA
FFIs, grandfathered obligation On October 24, 2012, the Internal Revenue Service (IRS) and the US Department of Treasury (Treasury) issued "Announcement 2012-42: Timelines for Due Diligence and Other Requirements under FATCA" (the Announcement).
United States
2 Nov 2012
New Proposed Regulations Treat Credit Default Swaps As Notional Principal Contracts
The US Department of the Treasury (the "Treasury") and the Internal Revenue Service (the "Service") issued proposed regulations on September 16, 2011 (the "proposed regulations") that, if finalized, will treat credit default swaps (CDSs) and certain other swaps as notional principal contracts (NPCs).
United States
14 Oct 2011
Internal Revenue Service Issues Guidance Extending FATCA’s Effective Date and Details a Timeline for Implementation
On July 14, 2011, the Internal Revenue Service (IRS) announced rules in Notice 2011-53 (the Notice) that modify FATCA’s January 1, 2013 statutory effective date, as a result of the comments submitted to the IRS and Treasury Department (Treasury) relating to the practical challenges of implementing FATCA by the statutory effective date.
United States
22 Jul 2011
Regulations Proposed by US Treasury Department and Internal Revenue Service Require Financial Institutions to Report Interest Paid to Nonresident Aliens
On January 7, 2011, the US Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations that would impose information collection and reporting requirements on US financial institutions with respect to bank deposit interest paid to non-US persons (the "2011 proposed regulations").
United States
17 Jan 2011
US IRS Issues Preliminary FATCA Guidance Establishing Due Diligence Procedures and Information Reporting Rules for Foreign Financial Institutions
On August 27, 2010, the US Internal Revenue Service (the "IRS") published Notice 2010-60 (the "Notice") containing preliminary guidance regarding implementation of the so-called FATCA rules.
United States
21 Sep 2010
IRS Chief Counsel Memorandum on Effectively Connected Income if Loan Origination Activity is Conducted Through a US Agent
On September 22, 2009, the Office of Chief Counsel of the Internal Revenue Service (the “Service”) issued a memorandum to the Director of Field Operations for Financial Services in Manhattan (the “Memorandum”) setting forth its position and legal analysis with respect to certain lending activities undertaken by foreign corporations.
United States
29 Sep 2009
US Internal Revenue Service Provides Limited Extension of Time to File FBAR
A United States person with a financial interest in, or signature authority over, “foreign financial accounts,” may be required to file a “Report of Foreign Bank and Financial Accounts” (Form TD F 90-22.1, or “FBAR”).
United States
2 Jul 2009
US IRS Suggests Certain United States Persons with Ownership of Non-US Investment Vehicles May Need to File Report of Foreign Bank and Financial Accounts
Several US Internal Revenue Service (IRS) officials have recently indicated that TD F 90-22.1 (Report of Foreign Bank and Financial Accounts) (FBAR) should be filed by United States persons that own interests in certain non-US investment vehicles, such as hedge funds.
United States
25 Jun 2009
2009 Economic Stimulus Package: Certain Debt Repurchases by Businesses Granted Relief from Tax on Cancellation of Indebtedneses Income
The economic stimulus package, signed into law on February 17, 2009, grants corporations and businesses that repurchase their debt at a discount a right, under certain circumstances, to elect to defer the recognition of their cancellation of indebtedness (COD) income for up to five years.
United States
24 Feb 2009
IRS Issues Guidance To Address Transactions In Distressed Market Conditions
The Internal Revenue Service (the “Service”) recently issued guidance intended to address certain situations arising as a consequence of the current market developments.
United States
7 Oct 2008
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