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New Timeline in Notice 2011-53 Is Intended to Respond to Concerns Expressed by Foreign Governments and Affected Entities Regarding New "FATCA" Rules

On February 8, Treasury released nearly 400 pages of highly detailed proposed regulations1 (the Proposed Regulations) relating to the implementation of the Foreign Account Tax Compliance Act (FATCA).

The past two decades has witnessed the "globalization" of the entertainment industry.

•The United Kingdom and the U.S. Competent Authorities have entered into a Competent Authority Agreement (the Agreement) under the bilateral U.K.-U.S. Income Tax Treaty (the U.K. Treaty)

On April 17, 2012, the Internal Revenue Service (the "IRS") issued final regulations requiring financial institutions to report to the IRS any payments of interest on deposits maintained at an office in the U.S. made to non-resident aliens who are residents of certain countries with which the U.S. has entered into exchange of information agreements.

Last May 4, President Trump and Prime Minister Turnbull celebrated the 75th anniversary of the Battle of the Coral Sea in New York aboard the USS Intrepid, a World War II aircraft carrier.

One key component of the OECD's Pillar One proposal to reallocate taxing rights from producer to consumer nations is the promise that businesses and governments...

The Maryland Tax Court struck down the state's digital advertising tax on multiple constitutional grounds, potentially establishing a precedent for challenging similar state taxes targeting the digital economy. The decisions address fundamental questions about how states can tax digital services without violating federal law and constitutional protections.

As a result of limited authoritative literature under United States ("U.S.") Generally Accepted Accounting Principles ("GAAP"), there has been a perception that significant diversity in the accounting for uncertain tax positions in the practice has developed over time.

For Americans and other foreign residents, Mexico is a very attractive country to live and work, because of its weather, rich culture, delicious food, friendly locals, and cost of living.

The Chancellor of the Exchequer delivered the United Kingdom ("UK") Budget for 2018 on 29 October 2018.

The rules would also make clear that ownership of a REIT by a QFPF does not count towards the domestic control requirement for D‑REIT status.

In the international tax context, the source of a taxpayer's income can have significant implications.

The current international tax system was established on principles dating back to the first half of the 19th century, when the internet did not exist and the economy mostly consisted of brick-and-mortar stores.

In this podcast, Brenda Coleman and Andy Howard discuss strategies for credit fund managers to address interest withholding tax issues on European investments in light of a complex and changing landscape.