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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...


HTMLProcess Is Its Own Reward: The IRS Modifies FATCA Effective Dates & Interim Compliance Standards
Jared B. Goldberger, Mark H. Leeds; Mayer Brown LLP;
Legal Alert/Article
May 12, 2014, previously published on May 5, 2014
On May 2, 2014, there were exactly 60 days until withholding and due diligence rules under the Foreign Account Tax Compliance Act (“FATCA”) became effective. Notwithstanding the fact that the US Internal Revenue Service (the “IRS”) has promulgated well over 1,000 pages of...


HTMLFATCA - The Time is Now: IRS Provides Limited Relief for Some Foreign Financial Institutions, But Many Will Need to Register by May 5
Daniel L. Gottfried; Hinckley, Allen & Snyder LLP;
Legal Alert/Article
April 30, 2014, previously published on April 23, 2014
The Foreign Account Tax Compliance Act (FATCA) was enacted as a component of the HIRE Act of 2010. Among other things, FATCA imposed a new 30% withholding tax with respect to certain payments made to any foreign financial institution (FFI), including a foreign bank, brokerage, or investment fund....


Adobe PDFEstate, Gift and Trust Provisions in New York State 2014-15 Budget: New York State 2014-15 Budget Makes Changes to the Taxation of Estates and Gifts and the Income Taxation of Certain Trusts
Sullivan Cromwell LLP;
Legal Alert/Article
April 15, 2014, previously published on April 4, 2014
On March 31, 2014, Governor Andrew Cuomo signed into law the New York State 2014-15 Budget (the “Budget”). This memorandum describes the changes made by the Budget to the taxation of estates and gifts and the income taxation of certain trusts. We will be distributing a separate...


HTMLIRS Says Bitcoin Isn’t Money
Joel Cazares; Sheppard, Mullin, Richter & Hampton LLP;
Legal Alert/Article
April 11, 2014, previously published on April 7, 2014
On March 25, 2014 the IRS issued Notice 2014-21, which describes how the IRS will interpret existing general tax principles to apply to transactions using “virtual currencies” such as Bitcoin. This Notice is the most recent in a line of similar regulatory pronouncements issued by...


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