May 2014

Who is a U.S. Person? Disparities between U.S. tax and immigration law

http://www.pbwt.com/files/Uploads/Documents/Who%20is%20a%20U.S.%20Tax%20Person_Bloomberg%20BNA.pdf?utm_source=Mondaq&utm_medium=syndication&utm_campaign=inter-article-link Note: The above reference link was live on May 2014, but it has since been taken down. Henry P. Bubel, Jenny Longman, Lisa M. Koenig, Nikki Dryden, and Michelle Mun˜oz-Machen Patterson Belknap Webb & Tyler LLP, Fragomen, Del Rey, Bernsen & Loewy LLP This article is intended to provide an overview of the intersection of

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Further Guidance on the Implementation of FATCA and Related Withholding Provisions

Extract of Commentary from Deloitte –   http://www.fsitaxposts.com/2014/05/03/notice-2014-33-limited-transition-relief-fatca-u-s-withholding-coordination-rules/ Note: The above reference link was live in May 2014, but it has since been taken down. On May 2, the U.S. Treasury and Internal Revenue Service released Notice 2014-33. Basically, the Notice provides for a so-called “soft open’, new entity accounts are given another 6 months,

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