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Documents on Taxation, Banking & Financial Services
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|Congress 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;
July 30, 2014, previously published on July 25, 2014This 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...
|Excess Lines Association of New York Advises on Foreign Account Tax Compliance Act (FATCA) Compliance|
Colodny Fass Talenfeld Karlinsky Abate Webb P.A.;
July 22, 2014, previously published on July 18, 2014In 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...
|Latest Swiss Cross-Border Tax Investigation Reflects Wider US Enforcement Agenda|
Ryan Dennis Junck, Sean P. Shecter; Skadden, Arps, Slate, Meagher & Flom LLP;
July 3, 2014, previously published on June 26, 2014Authorities 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...
|US 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;
June 30, 2014, previously published on June 20, 2014US 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...
|Highlights of the Québec Government's 2014-2015 Budget Relating to Businesses|
Angelo Discepola, Johnathan Landry, Marie-Soleil Landry, Ryan Rabinovitch; McCarthy Tétrault LLP;
June 11, 2014, previously published on June 5, 2014Following 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...
|Impact of FATCA on ORSO Schemes in Hong Kong|
Duncan A. W. Abate; Mayer Brown JSM;
May 29, 2014, previously published on May 27, 2014The 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...
|Process Is Its Own Reward: The IRS Modifies FATCA Effective Dates & Interim Compliance Standards|
Jared B. Goldberger, Mark H. Leeds; Mayer Brown LLP;
May 12, 2014, previously published on May 5, 2014On 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...
|FATCA - 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;
April 30, 2014, previously published on April 23, 2014The 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....
|Estate, 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;
April 15, 2014, previously published on April 4, 2014On 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...
|IRS Says Bitcoin Isn’t Money|
Joel Cazares; Sheppard, Mullin, Richter & Hampton LLP;
April 11, 2014, previously published on April 7, 2014On 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...