Kendal Aylor Sibley

Treasury Releases Proposed Regulations on FATCA
Cecelia Philipps Horner,George C. Howell,Alexander G. McGeoch,Mark A. Melton,Joshua Z. Mishoe,Kendal Aylor Sibley,B. Cary Tolley, February 20, 2012
On February 8, 2012, the Treasury Department and the Internal Revenue Service (“IRS”) issued proposed regulations with respect to the Foreign Account Tax Compliance Act (“FATCA”). FATCA requires certain persons making payments to foreign financial institutions...

Treasury Issues Proposed Regulations with Safe Harbor for Sovereign Wealth Funds
Cecelia Philipps Horner,George C. Howell,Mark A. Melton,Joshua Z. Mishoe,Kendal Aylor Sibley,B. Cary Tolley, November 22, 2011
On November 2, Treasury proposed regulations (the “Proposed Regulations”) under section 892 of the Internal Revenue Code (the “Code”) that eliminate the “all or nothing” rule that previously applied for determining whether an entity is a “controlled...

Stop Tax Haven Abuse Act
Cecelia Philipps Horner,George C. Howell,Alexander G. McGeoch,Mark A. Melton,Joshua Z. Mishoe,Kendal Aylor Sibley,B. Cary Tolley, August 1, 2011
On July 12, 2011, U.S. Senator Carl Levin, a Michigan Democrat, proposed a revised version of an international tax reform bill referred to as the Stop Tax Haven Abuse Act (the “Proposed Legislation”). The Proposed Legislation makes a number of changes to the current tax treatment of...