Tax Law

Recent Posts

Pepper Hamilton LLP Tax Update: Cut Unjustified Tax Loopholes Act Would Favor Foreign Fund Managers Over U.S. Managers
Posted on 9 Apr 2012 by Pepper Hamilton LLP

By Steven D. Bortnick and Timothy J. Leska , Attorneys, Pepper Hamilton LLP In March 2009, Sen. Carl Levin (D-Mich.) introduced the Stop Tax Haven Abuse Act (S. 506) (the 2009 Act) to "stop tax cheats" and target "off-shore tax abuses... Read More

Reporting Obligations of U.S. Beneficiaries of Foreign Trusts and New Form 8938
Posted on 20 Apr 2012 by Diane L. Mutolo

In 2010, Congress enacted the Foreign Account Tax Compliance Act (FATCA) as part of the Hiring Incentives to Restore Employment Act ("the HIRE Act"), and the legislation amended the Internal Revenue Code with the goal of increasing foreign account... Read More

FATCA Imposes Burdens on NFFEs
Posted on 22 Jan 2013 by LexisNexis Tax Law Community Staff

by Lawrence A. Kogan* The Foreign Account Tax Compliance Act of 2010 (FATCA) and its regs impose certain information gathering, reporting and withholding requirements on nonfinancial foreign entities (NFEEs) operated by U.S. taxpayers overseas. In part... Read More

Reporting Obligations of U.S. Beneficiaries of Foreign Trusts and New Form 8938
Posted on 18 Dec 2012 by Diane L. Mutolo

In 2010, Congress enacted the Foreign Account Tax Compliance Act (FATCA) as part of the Hiring Incentives to Restore Employment Act ("the HIRE Act"), and the legislation amended the Internal Revenue Code with the goal of increasing foreign account... Read More

Reporting Specified Financial Assets and Form 8938
Posted on 18 Dec 2012 by Neil Aragones

U.S. taxpayers with assets overseas and their advisers should be mindful of new Form 8938, Statement of Specified Foreign Financial Assets , as they prepare the taxpayers' federal income tax returns for 2011. Temporary Regulations issued in December... Read More

Pepper Hamilton LLP Tax Update: Cut Unjustified Tax Loopholes Act Would Favor Foreign Fund Managers Over U.S. Managers
Posted on 18 Dec 2012 by Pepper Hamilton LLP

By Steven D. Bortnick and Timothy J. Leska , Attorneys, Pepper Hamilton LLP In March 2009, Sen. Carl Levin (D-Mich.) introduced the Stop Tax Haven Abuse Act (S. 506) (the 2009 Act) to "stop tax cheats" and target "off-shore tax abuses... Read More

Definition Added to FATCA Requirements Landscape
Posted on 27 Feb 2012 by Neil Aragones

Proposed Regs Revise FATCA's Due Diligence Procedures: Pre-existing Individual Accounts and Electronic Searches The much-anticipated proposed regulations under the Foreign Account Tax Compliance Act (FATCA) have been issued by the Treasury, and... Read More

FATCA Compliance Programs
Posted on 24 Mar 2014 by William H. Byrnes IV

By Prof. William H. Byrnes and Dr. Robert J. Munro * Editor's Note: The following is an excerpt from Chapter 2 of the 2014 edition of LexisNexis Guide to LexisNexis® Guide to FATCA Compliance by William Byrnes and Robert Munro, published February... Read More

Reporting and Withholding Guidance: Payments to FFIs Under FATCA
Posted on 2 Apr 2012 by LexisNexis Tax Law Community Staff

Editor's Note : This narrative is derived from Tax Controversies: Audits, Investigations, Trials § 17.04 (Matthew Bender) by Robert S. Fink, J.D., LL.M., Kostelanetz & Fink, LLP, New York, N.Y. ... The Foreign Account Tax Compliance Act... Read More

Reporting Specified Financial Assets and Form 8938
Posted on 3 Apr 2012 by Neil Aragones

U.S. taxpayers with assets overseas and their advisers should be mindful of new Form 8938, Statement of Specified Foreign Financial Assets , as they prepare the taxpayers' federal income tax returns for 2011. Temporary Regulations issued in December... Read More

Definition Added to FATCA Requirements Landscape
Posted on 27 Feb 2012 by Neil Aragones

Proposed Regs Revise FATCA's Due Diligence Procedures: Pre-existing Individual Accounts and Electronic Searches The much-anticipated proposed regulations under the Foreign Account Tax Compliance Act (FATCA) have been issued by the Treasury, and... Read More

Reporting and Withholding Guidance: Payments to FFIs Under FATCA
Posted on 2 Apr 2012 by LexisNexis Tax Law Community Staff

Editor's Note : This narrative is derived from Tax Controversies: Audits, Investigations, Trials § 17.04 (Matthew Bender) by Robert S. Fink, J.D., LL.M., Kostelanetz & Fink, LLP, New York, N.Y. ... The Foreign Account Tax Compliance... Read More

Pepper Hamilton LLP Tax Update: Cut Unjustified Tax Loopholes Act Would Favor Foreign Fund Managers Over U.S. Managers
Posted on 9 Apr 2012 by Pepper Hamilton LLP

By Steven D. Bortnick and Timothy J. Leska , Attorneys, Pepper Hamilton LLP In March 2009, Sen. Carl Levin (D-Mich.) introduced the Stop Tax Haven Abuse Act (S. 506) (the 2009 Act) to "stop tax cheats" and target "off-shore tax abuses... Read More

FATCA Imposes Burdens on NFFEs
Posted on 22 Jan 2013 by LexisNexis Tax Law Community Staff

by Lawrence A. Kogan* The Foreign Account Tax Compliance Act of 2010 (FATCA) and its regs impose certain information gathering, reporting and withholding requirements on nonfinancial foreign entities (NFEEs) operated by U.S. taxpayers overseas. In... Read More

Reporting Obligations of U.S. Beneficiaries of Foreign Trusts and New Form 8938
Posted on 20 Apr 2012 by Diane L. Mutolo

In 2010, Congress enacted the Foreign Account Tax Compliance Act (FATCA) as part of the Hiring Incentives to Restore Employment Act ("the HIRE Act"), and the legislation amended the Internal Revenue Code with the goal of increasing foreign account... Read More