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New proposed legislation would add compliance costs and responsibilities for U.S. payors and affect non-U.S. recipients of U.S. source income.  The new legislation, called the Foreign Account Tax Compliance Act of 2009 (“FATCA” OR “FATCAT”), would apply to any outbound payment made on of after January 1, 2011.  FATCAT has the following key provisions: FATCAT […]

Effective November 6, 2009, the Worker, Homeownership, and Business Assistance Act of 2009 permits taxpayers to make an election carrying back net operating losses arising in 2008 or 2009 for up to 5 years.  Prior to the new legislation, net operating losses generally could only be carried back for up to 2 years.  The carryback […]

U.S. informational reporting requirements for U.S. persons who own shares of a foreign mutual fund  or  other “commingled fund” are remain unclear.  A U.S. person who invests in a foreign mutual fund through a foreign brokerage account is certainly required to report such ownership on their Form TD 90-22.1 (“FBAR”).  Reporting requirements for U.S.  persons […]

Protocol to U.S.-New Zealand income tax treaty sent to U.S. Senate.  The proposed protocol includes updates to rules on limitation of benefits, nondiscrimination, & information exchange.

President Obama clarified his proposed international tax reforms.  The President’s proposals would become effective in 2011 and raise a projected $210 million for the Federal government.  Highlights include: reformation of the so-called “check-the-box rules” as they apply to foreign entities reformation of the foreign tax credit so foreign income and the foreign tax credit are […]