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…

Securities Industry Group Seeks Swift Guidance on Treatment of New Equity Swaps Under HIRE Act Provision

The Securities Industry and Financial Markets Association May 11 asked the government for swift guidance on a newly enacted provision that would impose withholding tax on…

Congress Aware of Issues That Surround Statute of Limitations Provision, Aide Says

Members of Congress are aware of the issues surrounding a controversial provision on the statute of limitations in legislation to require broad new reporting by foreign banks, a lawyer on…

New Law Could Prevent Closing out Reserves for Some Tax Positions, Practitioners Fear

A new tax law seemingly intended to apply only to the statute of limitations for assessments on foreign information filed with the Internal Revenue Service could force financial statement preparers…

Guidance on Definitions, Scope, Carveouts Initial Focus under New Foreign Account Tax Compliance Act, IRS Official Says

Guidance on broad new requirements that foreign financial institutions report accounts with U.S.-owned assets to U.S. tax authorities is likely to focus first on carveouts and…

Foreign Accounting Tax Compliance Act’s 2013 Effective Date Due to Consideration of Foreign Law, JCT Staffer Says

The application of foreign law was a consideration when drafting the Foreign Accounting Tax Compliance Act, which contains a reasonable period of time for compliance on the part of…

IRS Focused on Timelines, Burdens in Implementing Foreign Accounting Tax Compliance Act Provisions, Top Official Says

Internal Revenue Service Associate Chief Counsel (International) Steven Musher April 26 said the agency remains focused on timelines and on imposing the least possible burden on taxpayers as it works to implement comprehensive…

New Foreign Bank Reporting Law Carries Broad Implications, Mayer Brown Attorneys Say

Legislation that will impose broad withholding and reporting requirements on foreign banks will affect a wide range of financial entities and raises big questions about identification of…

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