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Agencies Issue Final Rule Conforming Volcker Rule Regulations To 2018 Regulatory Relief Act
On July 22, 2019, five federal agencies (the "Agencies")[1] published a final rule (the "Final Rule"), which conforms the regulations implementing the Volcker Rule[2]
United States
31 Jul 2019
OFAC Delists Oligarch Companies Over Congressional Objections
On Sunday, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) announced that it lifted sanctions on three entities associated with Russian oligarch Oleg Deripaska ...
United States
1 Feb 2019
OCIE Publishes 2019 Enforcement Priorities
The SEC's Office of Compliance Inspections and Examinations (OCIE) published its 2019 examination priorities on December 20, 2018. Although OCIE's published priorities "provide a preview of key areas
United States
9 Jan 2019
Agencies Propose Conforming Amendments To Volcker Rule Regulations
On December 18, 2018, five federal agencies released a proposed rule ("Proposed Rule") to conform the regulations implementing the Volcker Rule to statutory modifications provided by Sections 203 and 204 ...
United States
2 Jan 2019
Agencies Propose A More Tiered Approach To Large Bank Supervision
On October 31, 2018, the federal banking agencies released two separate proposals that, if adopted, would create a more consistent tiered approach to large bank supervision ...
United States
26 Nov 2018
Opportunity Zone Proposed Regulations Issued – Provide Much Needed Clarification And Guidance
On October 19, 2018, the U.S. Treasury Department and IRS issued long-awaited and much anticipated proposed regulations relating to the OZ Fund rules contained in Section 1400Z-2 of the Internal Revenue Code.
United States
24 Oct 2018
Latest Treasury Action On Inversions Upends Pending Transactions And Surprises Many For Its Broad Scope And Use Of Questionable Authority
On April 4, 2016, the Treasury Department and the Internal Revenue Service issued a sweeping package of new regulations intended to curtail inversion transactions
United States
27 Apr 2016
Alternative Offshore Outsourcing Structures - February 2015
Offshore outsourcing retains an allure that the growth of hybrid cloud services and service integrator delivery models cannot entirely dispel.
United States
5 Feb 2015
The Inversion Craze: Will Today's Routine Tax Planning Be Retroactively Outlawed?
The media have been abuzz with reports on the latest so-called "inversion" transactions shifting a U.S.-based multinational corporation’s tax residence offshore.
United States
28 Jul 2014
IRS Issues Notice Signaling 2014 And 2015 As FATCA "Transition Period"
The IRS announced that calendar years 2014 and 2015 will be regarded as a "transition period" for purposes of enforcement and administration of FATCA.
United States
16 May 2014
WSJ Video: Regulators Focus On Reverse Churning By Advisers
Morrison & Foerster partner Daniel Nathan discusses how regulators plan to ferret out financial advisers who put clients in inappropriate fee-based accounts.
United States
1 Apr 2014
Managing Offshore Holding Companies From China: Recent Case May Suggest Increased Tax Risk
As our readers know, foreign investments into the People’s Republic of China ("PRC") are typically structured through one or more holding companies domiciled in offshore jurisdictions.
4 Nov 2013
China VIEs: Recent Developments And Observations
As many of our readers are aware, the "variable interest entity" ("VIE") structure has proven popular over the past decade as a means to facilitate the offshore financing of PRC companies doing business in regulated sectors such as the Internet and value-added telecommunications.
United States
19 Aug 2013
U.S. Treasury And Japan/Switzerland Announce They Will Negotiate Toward A Third Way For FATCA Compliance
As we have previously reported, the Foreign Account Tax Compliance Act ("FATCA") is becoming a significant concern to foreign banks, brokers and investment funds because of its potentially far reaching scope.
United States
29 Jun 2012
SAFE’s New Rule On Domestic Individuals’ Participation In Equity Incentive Schemes Of Offshore Listed Companies
China strictly regulates cross-border investments including both inbound and outbound investments.
21 Jun 2012
IRS Offshore Voluntary Disclosure Program Reopens
On January 9, 2012, the Internal Revenue Service (the "IRS") reopened indefinitely its offshore voluntary disclosure program (the "2012 OVDP") to assist taxpayers in reporting undisclosed foreign accounts, assets, and income.
United States
13 Jan 2012
Dodd-Frank Rulemaking Update: Resolution Plans/Living Wills
The July 6, 2011 Federal Deposit Insurance Corporation Board of Directors (the "FDIC Board") meeting marked the changing of the guard from Chairman Sheila Bair to FDIC Vice Chairman Martin Gruenberg.
United States
21 Jul 2011
IRS Considers New Partial Amnesty Program for Offshore Accounts: Strategic Considerations for Taxpayers
Taxpayers who hold any interest in, or signature authority over, a foreign bank account are required to indicate that on Schedule B of the Form 1040, and also file with the Treasury a Report of Foreign Bank and Financial Accounts, Form TD F 90-22.1 (the "FBAR" form).
United States
1 Feb 2011
Alternative Offshore Outsourcing Structures
In these troubled times, offshore outsourcing retains an allure for businesses. There are still significant savings to be attained from leveraging the benefits of lower offshore operating costs.
United States
4 Apr 2010
Foreign Account Tax Compliance Act Of 2009 – Congress Sets Its Sights On Overseas Tax Evasion
On October 27, 2009, Senator Max Baucus (D-Montana) and Representative Charles Rangel (D-New York), chairmen of the Congressional tax writing committees, introduced the Foreign Account Tax Compliance Act of 2009 (the “Bill”) in the U.S. Congress.
United States
8 Nov 2009
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