As the Tax Section celebrates its 75th anniversary, I was asked to reflect on the Section’s contribution in the international tax arena and on how the Section’s international community has grown. I started by recognizing the...more
5/12/2015
/ Cross-Border Transactions ,
FATCA ,
Foreign Taxpayers ,
International Tax Issues ,
OECD ,
Subpart F ,
Tax Credits ,
Tax Planning ,
Tax Policy ,
Tax Reform ,
Transfer Pricing
FATCA is the new form of 30% U.S. withholding tax that is applied to U.S. source income, such as interest and dividends paid by U.S. companies, starting as early as July 1, 2014 for payments made to non-U.S. entities that are...more
In response to taxpayer concerns about the practicality of meeting certain FATCA compliance timeline dates, the IRS, in Notice 2013-43 issued today, has extended some of those dates and made certain conforming changes. ...more
7/15/2013
/ Deferred Action ,
Dividends ,
FATCA ,
FATCA Timeline ,
FDAP ,
FFI ,
Foreign Banks ,
IGAs ,
IRS ,
Reporting Requirements ,
Withholding Requirements
In late October PE Manager brought together four industry professionals (Joan Arnold, Pepper Hamilton; Kristy Trieste, Corsair Capital; Lori Evans, Birch Hill Equity Partners; and Jay Bakst, EisnerAmper) who must all in their...more