Xiaoyang Ma
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On December 9, 2020, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice 2020-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain individuals with signature or other authority over (but no financial interest in) employer-owned foreign financial accounts to April 15, 2022. FinCEN has provided … Continue Reading
On December 20, 2019, the Financial Crimes Enforcement Network (“FinCEN”) issued Notice 2019-1, extending the filing deadline for the Report of Foreign Bank and Financial Accounts, FinCEN Form 114 (FBAR), for certain individuals with signature or other authority over (but no financial interest in) employer-owned foreign financial accounts to April 15, 2021. FinCEN has provided … Continue Reading
On May 13, 2019, the U.S. Internal Revenue Service (“IRS”) and Treasury Department published proposed regulations providing guidance on the rules imposing withholding and reporting requirements under the Code[1] on dispositions of certain partnership interests by non-U.S. persons (the “Proposed Regulations”). The Proposed Regulations expand and in important ways modify earlier Notice 2018-29[2] on dispositions … Continue Reading
Introduction On October 31, 2018, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (the “IRS”) proposed new regulations (the “Proposed Regulations”)[1] that are likely to allow many controlled foreign corporations (“CFCs”)[2] of U.S. multi-national borrowers to guarantee the debt of their parents and to allow the U.S. parent to pledge more than 66 … Continue Reading
Extension of FBAR Filing Deadline for Certain Filers
By Amanda H. Nussbaum, Abraham Gutwein and Xiaoyang Ma on Posted in International Taxation
Extension of FBAR Filing Deadline for Certain Filers
By Abraham Gutwein, Xiaoyang Ma, Amanda H. Nussbaum, Michael Fernhoff and David S. Miller on Posted in International Taxation
Section 1446(f) Proposed Regulations: Key Guidance on Partnership Interest Transfers by Non-U.S. Persons
By Jeremy Naylor, Martin T. Hamilton, David S. Miller, Amanda H. Nussbaum, Matthew Pincus, Xiaoyang Ma, Jeanette Stecker, Stephen Severo, Jean Bertrand, Scott S. Jones, Mary B. Kuusisto, Arnold P. May, Jamiel E. Poindexter and Stuart Rosow on Posted in International Taxation, IRS, Partnership Taxation, Tax Cuts and Jobs Act, Tax Reform, Withholding and FATCA
Impact of Proposed Regulations under Section 956 on Lending Arrangements Involving U.S. Corporate Borrowers
By Martin T. Hamilton, Annie Kim, David S. Miller, Xiaoyang Ma and Kathleen R Semanski on Posted in Corporate Taxation, International Taxation, IRS
