Category Archives: International Tax Alert

IRS Private Letter Ruling Holds that Pass-Through Interests in Mortgages Can Qualify as Registered Form Obligations

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In late January, the IRS issued a private letter ruling (P.L.R. 201504004) dealing with whether interests in a non-grantor trust and a partnership are considered to be in registered form, a precursor to qualification for payments thereon to the portfolio interest exemption. Although the ruling answers in the affirmative, it does not ultimately state whether the particular payments addressed in the ruling would be eligible for the portfolio interest exemption. To qualify for the portfolio interest exemption, and avoid U.S. withholding tax on payments of U.S.-source interest to a foreign person, [...]Read more

International Tax Alert: FACTA Delay!

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This alert discusses the IRS’ new timelines, in Notice 2013-43, for FATCA compliance in response to numerous concerns voiced worldwide about the timing of FATCA implementation. The full alert is provided on the Alston & Bird website: Written by Edward Tanenbaum, Partner, Federal & International Tax | Alston & Bird LLP [...]Read more

International Tax Alert: Final FATCA Regulations Are Finally Here

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This alert discusses the long-awaited final regulations under the Foreign Account Tax Compliance Act (FATCA) provisions in Code Sections 1471 to 1474 (also known as “Chapter 4”).

The advisory is provided in PDF on the Alston & Bird website: