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HTMLForeign Asset Disclosure, Financial Reporting and Tax Planning in a Complex World
Alison V. Lennarz; Kaufman & Canoles A Professional Corporation;
Legal Alert/Article
September 11, 2014
Globalization, and the interwoven economies of countries around the world that result from it, is only gaining momentum. Increasingly sophisticated communications and transportation technologies and services, mass migration and the movement of peoples, a level of economic activity that has outgrown...


HTMLNon-Dischargeable Tax Debt Not Special Class of Unsecured Creditors
Scott St. Amand, J. Ellsworth Summers; Rogers Towers, P.A.;
Legal Alert/Article
August 28, 2014, previously published on August 26, 2014
In numerous previous posts, we have noted that the purpose of the Bankruptcy Code is to help the “honest but unfortunate debtor.” Like gerrymandering, certain “creative” debtors have attempted to classify their non-dischargeable debt as a separate, special class of unsecured...


Adobe PDFChile and the United States Sign the Inter-Governmental Agreement ("IGA") Within the Scope of the Foreign Account Tax Compliance Act ("FATCA")
Diego Peralta, Jessica Power, Elena Yubero; Carey;
Legal Alert/Article
August 15, 2014
FATCA is a United States Act that requires US persons, including individuals who live outside the United States, to report their financial accounts held outside of the US, and requires foreign financial institutions ("FFIs") to report information regarding their US clients to the US...


HTMLNew Tax Rules for Loans Taken Out By UK Resident Non-Domiciliaries
Withers Bergman LLP/Withers LLP;
Legal Alert/Article
August 6, 2014, previously published on August 5, 2014
With effect from 4 August 2014, HMRC have changed, without notice, their stated position with respect to the treatment of commercial loans to UK resident and non-domiciled individuals. Action is required if individuals wish to avoid paying additional tax as a result of their existing arrangements.


HTMLCongress Scrutinizes Hedge Funds’ Use of Financial Derivatives
Bruce M. Bettigole, Thomas A. Cullinan, Yasho Lahiri, William R. Pauls, W. Scott Sorrels; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
July 30, 2014, previously published on July 25, 2014
This week the Senate Permanent Subcommittee on Investigations, Committee on Homeland Security and Governmental Affairs (Subcommittee), in conjunction with the Subcommittee’s hearing on July 22, 2014, released a report on hedge funds’ use of financial derivatives considered abusive. In...


HTMLExcess Lines Association of New York Advises on Foreign Account Tax Compliance Act (FATCA) Compliance
Colodny Fass Talenfeld Karlinsky Abate Webb P.A.;
Legal Alert/Article
July 22, 2014, previously published on July 18, 2014
In Bulletin No. 2014-15 issued yesterday, July 17, 2014, the Excess Lines Association of New York ("ELANY") responded to questions it has received to date about the implementation of the Foreign Account Tax Compliance Act ("FATCA"), which is scheduled to go into effect under its...


HTMLLatest Swiss Cross-Border Tax Investigation Reflects Wider US Enforcement Agenda
Ryan Dennis Junck, Sean P. Shecter; Skadden, Arps, Slate, Meagher & Flom LLP;
Legal Alert/Article
July 3, 2014, previously published on June 26, 2014
Authorities in the U.S. continue to crack down on foreign financial institutions that have allegedly aided U.S. taxpayers in evading their tax obligations. On May 19, 2014, Credit Suisse AG pled guilty to conspiracy to aid and assist U.S. taxpayers in filing false income tax returns and other...


HTMLUS Banking Regulators Issue Additional Guidance Regarding Tax Allocation Agreements in Holding Company Structures
Scott A. Anenberg, Hayden D. Brown, J. Paul Forrester; Mayer Brown LLP;
Legal Alert/Article
June 30, 2014, previously published on June 20, 2014
US banking regulators (the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency) have issued final joint supplemental guidance (Guidance) regarding tax allocation agreements involving holding companies and...


HTMLHighlights of the Québec Government's 2014-2015 Budget Relating to Businesses
Angelo Discepola, Johnathan Landry, Marie-Soleil Landry, Ryan Rabinovitch; McCarthy Tétrault LLP;
Legal Alert/Article
June 11, 2014, previously published on June 5, 2014
Following the defeat of the Parti Québécois on April 7, 2014, taxpayers were left facing some uncertainty with respect to the fate of Bill 55, which sought to introduce the Parti Québécois’ reform to the mining tax regime, which was to apply to fiscal years...


HTMLImpact of FATCA on ORSO Schemes in Hong Kong
Duncan A. W. Abate; Mayer Brown JSM;
Legal Alert/Article
May 29, 2014, previously published on May 27, 2014
The Foreign Account Tax Compliance Act (FATCA) is an invasive piece of US legislation. It is designed to identify tax avoidance being undertaken by US entities. It does this by imposing a 30 percent withholding tax on any US investments unless certain information is disclosed to the US tax...


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