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Troutman Pepper Locke

Section 899 Implications for Foreign Banks Lending to US Borrowers through US Lending Offices

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In an earlier alert, we described the potential impact of the One Big Beautiful Bill on withholding taxes imposed on loans made by foreign banks to U.S. borrowers. ...more

Foster Garvey PC

Disregarded Entities Under the Check-the-Box Regulations Are Not Disregarded for All Tax Purposes

Foster Garvey PC on

More than 25 years ago, effective January 1, 1997, Treasury issued what have been called the “Check-the-Box” regulations (the “Regulations”). The Regulations ended decades of battles between taxpayers and the IRS over entity...more

Farrell Fritz, P.C.

Business Resources and Recovery (UPDATED)

Farrell Fritz, P.C. on

Businesses grappling with the economic impact of the ongoing COVID-19 crisis have the opportunity to apply for financial assistance through a variety of Federal, State and Local programs. ...more

Stoel Rives LLP

Estate Planning and Income Tax Updates You Need to Know

Stoel Rives LLP on

Tax filing deadline. The Internal Revenue Service has issued Notice 2020-18 extending both the federal income tax filing and payment due dates for 2019 income tax returns from April 15, 2020 to July 15, 2020. These extensions...more

Ballard Spahr LLP

IRS Proposes To Eliminate ‘Confusing’ 36-Month Non-Payment Testing Period for Cancellation of Debt

Ballard Spahr LLP on

The Internal Revenue Service recently proposed very well-received regulations under Section 6050P of the Internal Revenue Code (the Code) that would eliminate the requirement for financial entities to treat debt as canceled...more

Blank Rome LLP

DOJ Offshore Enforcement Update: In Landmark Case, Credit Suisse Pleads Guilty, Agrees to Pay $2.6 Billion Penalty; Swiss Bank...

Blank Rome LLP on

Yesterday, the Department of Justice announced that Credit Suisse AG pleaded guilty to having assisted U.S. taxpayers in evading the payment of U.S. taxes and agreed to pay a penalty of $2.6 billion. Deputy Attorney General...more

Holland & Knight LLP

FBAR and Form 8938 Assistance Provided by Treasury

Holland & Knight LLP on

There are a multitude of information returns that United States taxpayers may need to file if they own foreign assets or have foreign investments. Two of these forms are the FBAR (Foreign Bank Account Report) and Form 8938...more

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