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Carol P. Tello Document Search Results (6) Sort by:  | FinCEN Extends Due Date for Certain FBAR Filers
Robert S. Chase, Dwaune L. Dupree, Amanda R. Pugh, Carol P. Tello; Sutherland Asbill & Brennan LLP;
Legal Alert/Article February 20, 2012, previously published on February 17, 2012 On February 14, 2012, the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued Notice 2012-1, which extended the filing deadline for both the 2010 and 2011 Report of Foreign Bank and Financial Accounts (FBARs) to June 30, 2013, for certain officers and employees with...
| | Getting Specific: IRS Issues Guidance on Withholding for Specified Notional Principal Contracts Under Section 871(m), Delays Statutory Effective Date
Robert S. Chase, David C. Cho, William R. Pauls, Leni C. Perkins, Amish M. Shah, Carol P. Tello; Sutherland Asbill & Brennan LLP;
Legal Alert/Article January 31, 2012, previously published on January 27, 2012 Section 871(m) generally treats “dividend equivalent” payments on securities lending transactions, repos and “specified notional principal contracts” as dividends from U.S. sources, which potentially are subject to U.S. withholding tax. Under the statute, until March 18,...
| | Proposed Section 892 Regulations Provide Relief From the “All or Nothing” Rule and Permit SWF Limited Partners to Avoid Commercial Activity Attribution
William H. Bradley, Dwaune L. Dupree, Daniel R. McKeithen, Carol P. Tello; Sutherland Asbill & Brennan LLP;
Legal Alert/Article November 11, 2011, previously published on November 8, 2011 Proposed regulations issued under Internal Revenue Code section 892, on November 2, 2011, address some of the most criticized rules under temporary regulations issued more than 20 years ago. Under the controlled commercial entity (CCE) regulations, engaging in even a de minimis amount of commercial...
| | It’s Just a Phase: The “Phased Implementation” of FATCA Under Notice 2011-53
Robert S. Chase, Dwaune L. Dupree, Michael R. Miles, William R. Pauls, Carol P. Tello; Sutherland Asbill & Brennan LLP;
Legal Alert/Article July 21, 2011, previously published on July 18, 2011 On July 14, 2011, Treasury and the Internal Revenue Service (IRS) released Notice 2011-53 (the Notice), which provides transition rules for implementation of the Foreign Account Tax Compliance Act (FATCA). Although the statutory effective date of the FATCA provisions is January 1, 2013, the...
| | Last Minute FBAR Extensions for “Signature Authority Only” Filers - Making Sense of the Announcements
Robert S. Chase, Dwaune L. Dupree, Michael B. Koffler, Susan S. Krawczyk, Holly H. Smith, Carol P. Tello, Mary Jane Wilson-Bilik; Sutherland Asbill & Brennan LLP;
Legal Alert/Article June 23, 2011, previously published on June 21, 2011 In the past week, two extensions for filing a Report of Foreign Bank and Financial Account (FBAR) were announced by the IRS and FinCEN for certain persons that are required to file FBARs solely as a result of their signature authority over a foreign financial account in which they have no financial...
| | FinCEN Extends FBAR Filing Deadline for Certain Officers and Employees - Does This Portend Changes?
Robert S. Chase, Dwaune L. Dupree, Susan S. Krawczyk, Holly H. Smith, Carol P. Tello, Mary Jane Wilson-Bilik; Sutherland Asbill & Brennan LLP;
Legal Alert/Article June 6, 2011, previously published on June 3, 2011 On May 31, 2011, in FinCEN Notice 2011-1, the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) extended the 2010 Report of Foreign Bank and Financial Accounts (FBAR) filing deadline from June 30, 2011, to June 30, 2012, for certain officers and employees with signature...
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