Dozens of Stakeholders Raise Concerns on Burdens of FATCA Regime

Dozens of foreign banks, foreign insurance companies, professional associations including several based in Washington, and other stakeholders around the world are asking the Internal Revenue Service for exceptions and clarifications…

Republican-Controlled House Expected to Shape Rulewriting Under Dodd-Frank

The full impact of the 2010 midterm elections is still being sorted out, but for financial services firms, what is clear is that the Republican-controlled House will be changing…

BNA INSIGHTS: Passive-Aggressive: IRS Releases Initial Guidance on FATCA Rules

Any attorney who has practiced law for some period of time has encountered co-counsel or opposing counsel who release a thick set of…

IRS Unveils Comprehensive Guidance on Foreign Bank Reporting, Disclosure

The Internal Revenue Service Aug. 27 unveiled eagerly awaited guidance on the implementation of the Foreign Account Tax Compliance Act (FATCA), which imposed a host of new requirements…

Senate Sends Financial Regulatory Reform Bill to White House for President’s Signature

The Senate voted 60-39 to approve legislation (H.R. 4173) July 15 that would overhaul regulation of banks and other financial services companies and change…

House Clears Financial Reform Bill Along Party Lines, Senate Action Delayed

The House approved landmark legislation (H.R. 4173) June 30 that would overhaul U.S. financial services regulation with new controls on large and interconnected financial…

BNA INSIGHTS: Governance of Enterprise Security: Carnegie Mellon CyLab 2010 Report

Today, the fiduciary duty directors and officers have to protect the assets of their organizations extends to digital assets, and has been…

Permanent Establishment Can Be Created Through Agency Relationship, IRS Official Says

The activities of companies that send agents into other countries to do business can create a permanent establishment for tax purposes even if the presence of agents does not…

Provisional Indemnification Receivables Includable in Foreign Insurer’s Subpart F Income, IRS Says

The Internal Revenue Service national office in Technical Advice Memorandum 201015030, released April 16, said provisional indemnification receivables (PIRs) for incurred but not…

IRS Chief Counsel Advice Addresses Interest Expense Allocable to Foreign Firm’s U.S. Insurance Business

The Internal Revenue Service Office of Chief Counsel, in a chief counsel advice memorandum released April 2, said a foreign taxpayer conducting a U.S. life insurance business must use the allocation method set forth in Treasury Regulations Section 1.882-5 to determine interest expense allocable to its U.S. branch for purposes of computing its U.S. income tax liability for 2001 and 2002 tax years.

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