BNA INSIGHTS: Collateral Damage: FATCA Implications For OTC Derivatives Supported by U.S. Dollar Assets

This article focuses on the FATCA implications of one seemingly small compliance issue—withholding on collateral arrangements. As our readers know, however, even a small falter can unseat riders…

FTC Proposes Changes to Children’s Online Privacy Protection Act Rule

The Treasury Department unveiled a long-awaited model agreement July 26 for government-to-government information sharing under the Foreign Account Tax Compliance Act (FATCA).

New Nonresident Alien Bank Reporting Rules Seen Hastening Automatic Information Exchange By Foreign Countries

New rules requiring U.S. banks to report interest on deposits held by nonresident aliens represent a significant advance in global information sharing and may be a factor in getting more countries to sign agreements to automatically exchange information with the United States, practitioners told BNA in recent interviews

IRS Unveils Final Rules Requiring Reporting Of Bank Interest Paid To Nonresident Aliens

Banks will have to report deposit interest paid to nonresident aliens as a way to help the United States combat tax evasion through its ability to reciprocate tax information shared by other countries, the Internal Revenue Service said in final rules (T.D. 9584).

IRS Hoping to Address Many Issues in First Guidance Under Foreign Account Tax Compliance Act

Internal Revenue Service Associate Chief Counsel Steven Musher June 3 said his agency is planning to include as many issues as it can in the first wave of guidance on legislation requiring broad…

BNA INSIGHTS: When the Other Shoe Falls: IRS Notice 2010-46 Restricts the Application of Notice 97-66 for Cross-Border Securities Loans

Notice 97-66 created an opportunity for non-U.S. financial institutions to participate in the securities lending markets for stocks of U.S. corporations without suffering…

IRS Withdraws Guidance Implementing Cross-Border Securities Transaction Rules

The Internal Revenue Service May 20 issued Notice 2010-46, withdrawing 1997 guidance that generally limited the aggregate U.S. gross basis tax on a series of securities lending…

Government Still Looking at Asset Threshold Issue in Uncertain Tax Positions Proposal

The government continues to wrestle with the question of how a $10 million asset threshold for those required to disclose uncertain tax positions under a new proposal will apply to…

American Institute of Certified Public Accountants Offers Comments to Treasury, IRS on Foreign Bank Account Report Guidance

The American Institute of Certified Public Accountants May 17 unveiled comments on requirements for taxpayers required to file the Report of Foreign Bank Account (FBAR) …

Pace of Change in Cross-Border Transparency Initiatives Increasing, IRS Official Says

The pace of change in the new world of increased transparency and information exchange has “accelerated on all fronts,” Internal Revenue Service Deputy Associate Chief Counsel (International) Theodore…

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