Some of the provisions of the Patient Protection and Affordable Care Act—ones that have already taken effect as part of the 2010 health reform legislation—could be here to stay. Depending on how the justices rule, employers could be in for bigger changes starting in 2014.
The acronym for the US Foreign Account Tax Compliance Act—FATCA—is easy to remember if one thinks of “fat cat.” Unfortunately, this may be the only thing about FATCA that is easy. This item highlights the provisions of FATCA that are most likely to affect US tax practitioners and their clients, the taxpayer reporting provisions of new Section 6038D of the Internal Revenue Code.
The US Internal Revenue Service issued final regulations under Sec. 6049 outlining the rules requiring US financial institutions to report interest payments to certain nonresident alien individuals of $10 or more per year paid after December 31st 2012.
The US Treasury Department’s Internal Revenue Service (IRS) announced a reorganisation of its advance pricing agreement (APA), mutual agreement and competent authority programmes into one new programme.
The US Treasury Department’s Financial Crimes Enforcement Network announced that it is postponing until July 1st 2013 its requirement that Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), be filed electronically.
Late Thursday, the IRS issued final regulations on determining who has the legal liability to pay the foreign tax for foreign tax credit purposes (T.D. 9576) and temporary regulations on the application of the “anti-splitter” rules of Sec. 909 (T.D. 9577). The rules are related because the legal liability to