U.S. Law Watch » Withholding http://www.uslawwatch.com U.S. Legal & Regulatory Headlines Thu, 26 Jan 2012 18:07:29 +0000 en hourly 1 http://wordpress.org/?v=3.3.1 IRS Hoping to Address Many Issues in First Guidance Under Foreign Account Tax Compliance Act http://www.uslawwatch.com/2010/06/04/tax/irs-hoping-address-issues-guidance-foreign-account-tax-compliance-act/ http://www.uslawwatch.com/2010/06/04/tax/irs-hoping-address-issues-guidance-foreign-account-tax-compliance-act/#comments Fri, 04 Jun 2010 14:15:52 +0000 admin http://www.uslawwatch.com/?p=2257

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 new reporting and disclosure from foreign banks about their U.S. account holders.

Speaking to the Federal Bar Association Section of Taxation at an insurance conference, Musher said IRS will address, “as far as we can,” the question of which classes of financial institutions will be required to disclose under the rules and which will be carved out.

In response to questions, the IRS official said it is too soon to say whether various types of insurance companies would be candidates for the latter category under the new law. The statute implemented the provisions of the Foreign Account Tax Compliance Act under the Hiring Incentives to Restore Employment (HIRE) Act (Pub. L. No. 111-147), signed into law March 18 (52 DTR GG-1, 3/19/10).

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]]> http://www.uslawwatch.com/2010/06/04/tax/irs-hoping-address-issues-guidance-foreign-account-tax-compliance-act/feed/ 0 BNA INSIGHTS: When the Other Shoe Falls: IRS Notice 2010-46 Restricts the Application of Notice 97-66 for Cross-Border Securities Loans http://www.uslawwatch.com/2010/06/03/tax/bna-insights-shoe-falls-irs-notice-201046-restricts-application-notice-9766-crossborder-securities-loans/ http://www.uslawwatch.com/2010/06/03/tax/bna-insights-shoe-falls-irs-notice-201046-restricts-application-notice-9766-crossborder-securities-loans/#comments Thu, 03 Jun 2010 11:03:15 +0000 admin http://www.uslawwatch.com/?p=2238

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 burdensome U.S. federal withholding taxes.

Congress perceived, however, that the withholding tax relief provided by Notice 97-66 created an opportunity for an avoidance of such withholding taxes. The first shoe fell in March, when Congress repealed Notice 97-66, effective for substitute dividend payments made on or after Sept. 14, 2010. The other shoe fell May 20 when the Internal Revenue Service (IRS) released Notice 2010-46. Notice 2010-46 substantially restricts the application of Notice 97-66 effective immediately, that is, for substitute dividend payments made on or after May 20, 2010. Notice 2010-46 also provides relief from cascading withholding in limited circumstances.

This article describes the new notice and its effect on both pre- and post-Sept. 14, 2010, securities lending transactions.

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]]> http://www.uslawwatch.com/2010/06/03/tax/bna-insights-shoe-falls-irs-notice-201046-restricts-application-notice-9766-crossborder-securities-loans/feed/ 0 IRS Withdraws Guidance Implementing Cross-Border Securities Transaction Rules http://www.uslawwatch.com/2010/05/24/tax/irs-withdraws-guidance-implementing-crossborder-securities-transaction-rules/ http://www.uslawwatch.com/2010/05/24/tax/irs-withdraws-guidance-implementing-crossborder-securities-transaction-rules/#comments Mon, 24 May 2010 15:05:50 +0000 admin http://www.uslawwatch.com/?p=2154

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 transactions to no more than 30 percent of the amount equivalent to…

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]]> http://www.uslawwatch.com/2010/05/24/tax/irs-withdraws-guidance-implementing-crossborder-securities-transaction-rules/feed/ 0 Securities Industry Group Seeks Swift Guidance on Treatment of New Equity Swaps Under HIRE Act Provision http://www.uslawwatch.com/2010/05/20/tax/securities-industry-group-seeks-swift-guidance-treatment-equity-swaps-hire-act-provision/ http://www.uslawwatch.com/2010/05/20/tax/securities-industry-group-seeks-swift-guidance-treatment-equity-swaps-hire-act-provision/#comments Thu, 20 May 2010 13:30:07 +0000 admin http://www.uslawwatch.com/?p=2107

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…

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]]> http://www.uslawwatch.com/2010/05/20/tax/securities-industry-group-seeks-swift-guidance-treatment-equity-swaps-hire-act-provision/feed/ 0 Congress Aware of Issues That Surround Statute of Limitations Provision, Aide Says http://www.uslawwatch.com/2010/05/10/tax/congress-aware-issues-surround-statute-limitations-provision-aide/ http://www.uslawwatch.com/2010/05/10/tax/congress-aware-issues-surround-statute-limitations-provision-aide/#comments Mon, 10 May 2010 11:10:54 +0000 admin http://www.uslawwatch.com/?p=1947

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…

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]]> http://www.uslawwatch.com/2010/05/10/tax/congress-aware-issues-surround-statute-limitations-provision-aide/feed/ 0 New Law Could Prevent Closing out Reserves for Some Tax Positions, Practitioners Fear http://www.uslawwatch.com/2010/05/10/tax/law-prevent-closing-reserves-tax-positions-practitioners-fear/ http://www.uslawwatch.com/2010/05/10/tax/law-prevent-closing-reserves-tax-positions-practitioners-fear/#comments Mon, 10 May 2010 11:00:56 +0000 admin http://www.uslawwatch.com/?p=1945

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 to indefinitely maintain reserves booked against uncertain tax positions, practitioners said.

The growing concern about maintaining the reserves on financial statements—along with indefinite liability for tax assessments from a misstated tax advantage or liability filed anywhere on the tax return—grows out of a package of tax code amendments that President Obama signed into law March 18…

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]]> http://www.uslawwatch.com/2010/05/10/tax/law-prevent-closing-reserves-tax-positions-practitioners-fear/feed/ 0 Guidance on Definitions, Scope, Carveouts Initial Focus under New Foreign Account Tax Compliance Act, IRS Official Says http://www.uslawwatch.com/2010/05/04/tax/guidance-definitions-scope-carveouts-initial-focus-foreign-account-tax-compliance-act-irs-official/ http://www.uslawwatch.com/2010/05/04/tax/guidance-definitions-scope-carveouts-initial-focus-foreign-account-tax-compliance-act-irs-official/#comments Tue, 04 May 2010 14:00:34 +0000 admin http://www.uslawwatch.com/?p=1871

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 issues of definition and scope, a senior Internal Revenue Service official said April 30…

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]]> http://www.uslawwatch.com/2010/05/04/tax/guidance-definitions-scope-carveouts-initial-focus-foreign-account-tax-compliance-act-irs-official/feed/ 0 Foreign Accounting Tax Compliance Act’s 2013 Effective Date Due to Consideration of Foreign Law, JCT Staffer Says http://www.uslawwatch.com/2010/04/30/tax/foreign-accounting-tax-compliance-acts-2013-effective-date-due-consideration-foreign-law-jct-staffer/ http://www.uslawwatch.com/2010/04/30/tax/foreign-accounting-tax-compliance-acts-2013-effective-date-due-consideration-foreign-law-jct-staffer/#comments Fri, 30 Apr 2010 16:45:38 +0000 admin http://www.uslawwatch.com/?p=1849

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 foreign banks as a result, a Joint Committee on Taxation legislative counsel said April 29…

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]]> http://www.uslawwatch.com/2010/04/30/tax/foreign-accounting-tax-compliance-acts-2013-effective-date-due-consideration-foreign-law-jct-staffer/feed/ 0 IRS Focused on Timelines, Burdens in Implementing Foreign Accounting Tax Compliance Act Provisions, Top Official Says http://www.uslawwatch.com/2010/04/27/tax/irs-focused-timelines-burdens-implementing-foreign-accounting-tax-compliance-act-provisions-top-official/ http://www.uslawwatch.com/2010/04/27/tax/irs-focused-timelines-burdens-implementing-foreign-accounting-tax-compliance-act-provisions-top-official/#comments Tue, 27 Apr 2010 12:32:02 +0000 admin http://www.uslawwatch.com/?p=1791

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 reporting and disclosure requirements for foreign banks under provisions of the Foreign Accounting Tax Compliance Act…

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]]> http://www.uslawwatch.com/2010/04/27/tax/irs-focused-timelines-burdens-implementing-foreign-accounting-tax-compliance-act-provisions-top-official/feed/ 0 New Foreign Bank Reporting Law Carries Broad Implications, Mayer Brown Attorneys Say http://www.uslawwatch.com/2010/04/19/tax/foreign-bank-reporting-law-carries-broad-implications-mayer-brown-attorneys/ http://www.uslawwatch.com/2010/04/19/tax/foreign-bank-reporting-law-carries-broad-implications-mayer-brown-attorneys/#comments Mon, 19 Apr 2010 13:54:17 +0000 admin http://www.uslawwatch.com/?p=1675

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 non-U.S. account holders, two practitioners from Mayer Brown LLP said April 15.

Both Thomas Delaney and Jonathan Sambur said…

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