|
|
|
|
||
|
||
|
Vol. 94, Nos. 1-26, pp. 1-1312, and Vol. 95, Nos. 1-23, pp. 1-1148 Jan. 5 -- Dec. 21, 2010 A | B | C | D | E | F | G | H | I | J | K | L | M | N | O | P | Q | R | S | T | U | V | W | X | Y | Z
TALF
– Disclosure of interests in foreign accounts, DOJ investigation of HSBC account holders, 95:49; DOJ letters likely precursor of trouble for bank, 95:49
– Discrimination against U.S. clients by Swiss banks following tax crackdown, senior Swiss regulator remarks, 94:630 – Enforcement policy
– – Congressional actions
– – – Continuation of benefits, taxpayer and practitioner requests, 95:1023
– – – Critical assessment, BNA Insights, 95:592 – – Offshore compliance, announcement of major focus of IRS scrutiny, 94:757 – – Use of IRS information gained through voluntary disclosure of offshore assets, 94:163; large number of cases likely closed soon, 94:973 – Foreign Account Tax Compliance Act (FATCA)
– – Dividend equivalent deals, American Bar Ass'n recommendation of flexibility to IRS, 95:796
– – Financial intermediaries, request to IRS for clarification of tax treatment, 95:627 – – Foreign bank reporting rules, comprehensive IRS guidance, 95:343; comments to IRS include request for more and broader exceptions, 95:740 – – Implementation, IRS seeking comments, 94:691; CFC exemption absent from rules, 95:449; guidance on reportable payments and grandfather rules under consideration, 95:456; Treasury Dep't and IRS guidance documents necessary before foreign bank pacts, 95:841 – – Insurance and holding company issues, Treasury Dep't and IRS consideration of complex questions, 95:353 – – Repeal of foreign exceptions to bond registrations could create difficulties in European bond market, 95:174 – Foreign tax credits, Treasury Dep't priorities, 94:142 – G-20, France continuing surveillance during presidency, 95:896 – Group relief under foreign credit splitter provisions, IRS and Treasury Dep't consideration of issues, 95:627 – Illicit financial flows, watchdog group report, 94:990 – Information exchange standard, OECD global forum on progress, 95:589 – Liechtenstein Global Trust annual report, FY2009, 94:583 – Multinationals' tax evasion, impact on small businesses, interest group report, 95:156 – Offshore asset cases, Wagner remarks, 94:1297 – Outflows likely to reverse despite commitment on assets, Swiss banking chief remarks, 94:1212 – Passive foreign investment company (PFIC) issues, IRS method for dealing with enforcement role in international crackdown, 95:448 – Reporting, implementation of requirements for foreign financial institutions, 94:473 – Subpart F, Treasury Dep't priorities, 94:142 – Tax treaties
– – Switzerland-Germany double tax pact, agreement near on initiation of formal talks, 95:760; negotiation agreement signed, 95:807; initial success means more agreements likely, 95:854
– – Switzerland-UK negotiations over withholding taxes on assets in Swiss banks, 95:806 – – Withholding foreign tax, Swiss bank estimates on outflows from new international deals, 95:946; bank executive remarks, 95:1036
– – Deadline for handing over names marks new disclosure landscape, Analysis and Perspective, 95:375
– – Developing aftermath of tax evasion case, BNA Insights, 95:647 – – FBAR penalties, 7 clients charged with hiding more than $100M (S.D.N.Y.), 94:764 – – Financial adviser charged with tax fraud conspiracy for alleged scheme to persuade U.S. client from disclosing account (S.D. Fla.), 95:1128 – – Former client sentence for hiding account from IRS (S.D.N.Y.), 95:527 – – Recouping $37M from bank for cost of implementation of U.S. tax deal, Swiss proposals, 94:889 – – Shareholders' refusal to shield former board of directors and management from possible legal action, 94:764; denial of discharge to members of 2007 board, 94:769 – – Swiss financial market agency authority exceeded in ordering transfer of client data to U.S. tax authorities, 94:75; court ruling, 94:116; exclusion of some data from handover to IRS, 94:157; data on 250 secret accounts in handover, 94:234; urgent talks to continue, 94:244; U.S. unwilling to renegotiate data disclosure deal, 94:307; further rulings declined, 94:486; UBS lobbying for approval of tax accord with U.S., 94:531; Leuthard calls ratification of agreement important, 94:631; push for parliamentary approval of deal, 94:767; appeal of court ruling rejected, 94:818; parliamentary commission recommendation, 94:823; increased chances for parliamentary approval of agreement, 94:1105; upper legislative house approval of deal, 94:1145; second upper legislative house approval of deal, 94:1206; final approval to agreement without referendum, 94:1264; court order for reconsideration of clients' appeal to information exchange, 95:170; deadline for processing accounts met but handover not complete, 95:344 – – Tax fraud allegations, IRS withdraws “John Doe” summons, 95:910 – – Whistleblowers, former banker's prison term postponement and sentence reduction request (S.D. Fla.), 94:25; allegedly incomplete and misleading statements by DOJ attorneys during sentencing hearing, 94:75; dismissal of government's case leads to questions of next IRS target, 95:745
– Fraud, former Ernst & Young partners scheme to market sham shelters (S.D.N.Y.), 94:160
– ARRA corrections, National Ass'n of Bond Lawyers suggestions relating to Build America Bonds and other bonds, 94:869
– Bank supervision, American Bar Ass'n Tax Section discussion, 94:146 – Carried interest – Credit card interest, temporary income tax deduction – Debt instruments, IRS proposed rules on recharacterization of modified instruments, 94:1128 – Equity swaps with non-U.S. counterparties, new IRS audit guidelines, BNA Insights, 94:389 – Exit taxes on sale or transfer of property used as affordable housing – Extension of certain tax provisions during lame-duck session, community bank request, 95:794 – Failed banks
– – Nonperforming loans, new tax policy issue, IRS official remarks, 95:512
– – Tax treatment of FDIC-assisted acquisitions, NYSBA Tax Section suggestions, 94:878 – Financial Account Tax Compliance Act (FATCA) provisions, IRS intial guidance on rules, BNA Insights, 95:477; impact on withholding agents and financial institutions, 95:520; stakeholder concerns on burdens, Special Report, 95:952 – Financial Crisis Responsibility Fee, Pres. Obama bank tax proposal, 94:87; Rangel (D-NY) and Frank (D-Mass) plans for implementing measure, 94:129; possible impact of Brown victory in Mass, 94:143; Grassley (R-Iowa) request for CBO and JCT analysis of proposal, 94:144; American Bar Ass'n Tax Section discussion, 94:145; cooperation with G-20 countries under discussion, 94:162; Spain and EU likely to examine proposal, 94:162; Gregg (R-NH) criticism of proposal, 94:264; interest group discussion, 94:312; Neal (D-Mass) exemptions proposal, 94:419; CBO estimates, 94:466; Hill Watch, 94:712; coaltion of stakeholders supporting proposal, 94:756; Baucus (D-Mont) comments, 94:796; Sobel remarks, 94:863; Geithner remarks, 94:902; Senate Finance Comm. hearing witness list, 94:930; FRB Minneapolis president suggestion, 94:964; impact on Fannie Mae and Freddie Mac, 94:965; AFL-CIO push for tax, 95:18 – Financial transaction tax – Foreign bank and financial accounts report (FBAR)
– – AICPA recommendations for expanding and adding exemptions and other clarifying changes, 95:987
– – Broad implications of withholding and reporting requirements, Mayer Brown remarks, 94:770 – – Employee benefit plans, comments on impact on pensions, 94:872 – – Examination of central provision of FATCA portion of HIRE Act, BNA Insights, 94:776 – – Exclusion of certain financial institutions from broad new requirements, stakeholder requests, 95:310 – – IRS targeted guidance, 94:417 – – Sourcing rules, implications of changes under FATCA, 95:311 – Health care reform, new tax obligations, impact on international employees, 95:279 – Home Affordable Modification Program, related tax issues, BNA Insights, 95:37 – Insurance, formal guidance on claims for dividends-received deductions under consideration, 94:1140 – New markets tax credits, IRS ruling on qualified equity investments made by LLCs classified as partnership, 94:1183 – Nonperforming loans, identification of accrual of interest income, IRS industry directive, 94:618 – OECD code of conduct for banks under development, 94:626 – Passive foreign investment company rules, N.Y. State Bar Ass'n Tax Section recommendations for narrower bank and financial institution rules, 94:525 – Permanent home mortgage insurance premiums deduction – Refund anticipation loans
– – Debt indicator, IRS plans for 2010 tax filing season, 95:273
– – Jackson Hewitt Tax Serve attempt to stop state investigation dismissed (S.D.N.Y.), 95:364 – – Regulatory reform, final cross-government working group recommendations soon, 94:970 – – Trends of lenders participating in market, executive remarks, 94:1128 – Safe harbor for deferred reporting of gain or loss by taxpayers unable to complete like-kind exchange due to defaulting qualified intermediary, 94:476 – Sale or exchange of nonpublicly traded property, §1274A debt instruments, ruling on IRS inflation adjustments, 95:1069 – Saver's Credit expansion, Hill Watch, 94:712 – Stock of foreign issuers, payments by domestic firms for expenses incurred in setting up sponsored American Depositary Receipts program count as gross income, 95:1120 – Subchapter S corporations
– – Excise tax on high employee bonuses at certain Wall Street firms, Boxer (D-Cal) and Webb (D-Va) proposed measure, 94:276; further action, see LEGISLATION, FEDERAL, HR 4213
– – §382 treatment of assets acquired by government, block of IRS Notice 2010-2 on Citigroup tax benefits – Tax extenders measure, ICBA support for deal, 95:1064 – UK, guidance on proposed bank bonus tax, 94:31; plans moving forward on bank payroll tax proposal, 94:626 – Unbanked and underbanked individuals, IRS rule allowing direct deposits of tax refunds, 95:394; financial sector eager to participate, 95:518 – Uncertain tax positions, IRS proposal for proactive reporting with tax returns, 94:218; plan seen changing landscape of disclosure, BNA Insights, 94:294; proposal not applicable to taxes other than U.S. federal income taxes or passthrough entities, 94:366; likely strain in relationships between businesses, accountants, and tax advisers forecast, 94:425; intent on fine-tuning audit process, 94:474; N.Y. State Bar Ass'n group concerns about proposal, 94:655; guidance soon on requirements for large corporate taxpayer reporting, 94:697; disclosure not trigger for IRS action, 94:793; impact of draft schedule and instructions to taxpayers, Analysis and Perspective, 94:831; allegedly intentional avoidance of litigation check box on draft schedule, 94:844; targeted information apparent part of IRS requirements, 94:924; transfer pricing implications, 94:940; stakeholder criticism of proposal, 94:1121; text, 94:1154; Wilkins remarks on range of issues with reporting plan, 94:1177; policy of restraint regarding tax accrual work papers, 94:1244; more taxpayer criticism, 94:1245; Schedule UTP not analysis tool, 94:1300; concerns about potential impact on information privilege, 95:220; facts-based approach necessary, Meighan remarks, 95:352; IRS proposed disclosure rules, 95:393; IRS schedule revisions for maximum tax adjustment and reporting requirements, 95:499; changes to disclosure plan focusing on paperwork burden and attorney-client privilege, 95:500; IRS guidance with focus on certainty, 95:628; revised guidance helpful but concerns remain, witness remarks, 95:687; IRS plan focused on information over intent, Shulman remarks, 95:795; IRS focus on basis of reporting, 95:886; more IRS guidance likely, 95:929; Wilkins remarks, 95:1067; foreign issues disclosure requirements, 95:1068; authority to require disclosure in final rules, 95:1119 – Wells Fargo participation in SILO shelter, tax refund denied (Fed. Cl.), 94:71
– Breach of fiduciary duty, Regions Financial and affiliates, offering of proprietary mutual funds in retirement plans while reaping kickbacks (W.D. Tenn.), 94:528
– Guarantee lowering, Treasury Dep't announcement, 95:157
– Mortgage-backed securities, smooth ending to FRB program, 94:644
– EU, bank wire transfer data for counterterrorism purposes, new mandate for negotiations with U.S., 94:625
– Financing
– – Beneficial ownership information for certain accounts, SEC statement and guidance, 94:522
– – Europisch-Iranische Handelsbank, Treasury Dep't designation as key financial lifeline for Iran, 95:420 – – Prevention, House Financial Servs. panel hearing, testimony on improvements to financial crimes reporting, 95:577 – Spain, harmonization with EU terror financing standards, 94:890
– Consumer protection
– – Senior citizens, protection from foreclosure suit following filing of deferment of property taxes, 95:233
– – Woodforest Bank of Refugio, settlement agreement with OTS over unfair overdraft protection fees, 94:800
– – Franklin Bank, S.S.B., of Houston, FDIC note offering closed, 94:800
– – La Coste Natl. Bank in La Coste, 94:420
– – Kappa Alpha Psi FCU in Addison, 95:262
– – Orange County Employees Credit Union in Orange County, 94:1190 – – Phil-Pet FCU in Pampa, 95:731
– Uncertain tax positions, comments of coalition of banking and business groups on 3 IRS announcements, 94:1154
– Appointments and personnel changes
– – Allison resignation as top TARP official, 95:522
– – Barr departure from assistant secretary for financial institutions post, 95:975 – – DuChene as deputy Comptroller of Currency for Operational Risk Policy, 95:109 – – Dugan resignation as Comptroller of Currency, 94:54 – – Goldstein as undersecretary for domestic finance, 94:477 – – Lybarger as OCC deputy for licensing, 95:408 – – Walsh as acting Comptroller of Currency, 95:147 – – Ward as deputy Comptroller of Currency for Thrift Supervision, 95:831 – Debt management, reduction in size of quarterly refunding auctions, 94:913; primary dealer concerns about direct auction bidders, 94:1023 – OCC absorption of OTS, some OTS regulations carrying over into new regime, Williams remarks, 95:830
– Accounting, forecasted earnings from bank loans, 94:52
– Asset disposal plan, Congressional Oversight Panel criticism, 94:95 – Bailouts, no further programs necessary, Geithner remarks, 94:1287 – BoA warrants, Treasury Dep't auction plans, 94:354; record amount of net proceeds from sales, 94:465; praise for Treasury Dep't sales, 94:962 – Capital Purchase Program
– – Common stock shares, Treasury Dep't sales plans, 94:604; transaction totals, 94:1082; continued reduction in portfolio, 95:13
– – Profits from government aid while public benefits debated, Analysis and Perspective, 95:241 – – Trust preferred securities (TRUPS), additional Treasury Dep't sales of equity, 95:563 – Cost estimate, updated CBO estimate, March 5 report, 94:507; March 17 report, 94:563; Aug. 20 report, 95:362; Treasury Dep't report, 95:618 – Executive compensation
– – Cuomo letters requesting bonus data from 8 banks, 94:105
– – Excise tax on high employee bonuses at certain Wall Street firms, Boxer (D-Cal) and Webb (D-Va) proposed measure, 94:276; further action, see LEGISLATION, FEDERAL, HR 4213 – – Special master review of packages paid to bailed-out bank employees since Feb. 2009, 94:601 – GMAC Financial Services
– – COP report, 94:520
– – Partial repayment of bailout funds, 94:653 – Housing Finance Agency Innovation Fund for Hardest Hit Housing Markets, more allocations for select states, 94:650 – Legacy, questions as program officially expires, Analysis and Perspective, 95:604 – Losses, Treasury Dep't confidence in long-term profits, 94:404 – Moral hazard legacy as long-lasting cost of program, Congressional Oversight Panel report, 95:460 – Overseas flow of funds, Congressional Oversight Panel recommendations, 95:305 – Recoupment responsibility, Congressional clarification of language, Barofsky remarks, 95:939 – Small businesses
See SMALL BUSINESSES
– Taxation, §382 treatment of assets acquired by government, block of IRS Notice 2010-2 on Citigroup tax benefits – Volume of new loans, Treasury Dep't data, Nov. 2009, 94:142 Contact the Webmaster at webmaster@bna.com Copyright © The Bureau of National Affairs, Inc. All Rights Reserved. |
