News 24 Jun. 2021
Curtis successfully defends foreign states' procedural privileges in the UK Supreme Court
News 23 Jun. 2021
Ibrahim Elsadig joins Curtis as Partner in Dubai
News 09 Aug. 2021
Curtis, Mallet-Prevost, Colt & Mosle enters into association with Chevalier Law in Singapore.
Event 23 Apr. 2021
Partner Borzu Sabahi to speak on Damages, Enforcement and Annulment of Arbitral Awards at Executive Training Program hosted by the Government of India and the Indian Institute of Foreign Trade
Client Alert 18 Oct. 2021
Senior Associate Martin Wolff Discusses Practical Questions with Regard to the German Implementation of the EU Directive on Cross-Border Tax Arrangements (DAC6) in Institutional Money
News 18 Oct. 2021
Jan Krupski Joins Curtis as a Partner in Frankfurt
News 15 Oct. 2021
Claudia Frutos-Peterson and Elisa Botero Ranked Among the Top 100 Female Lawyers in Latin America by Latinvex
News 13 Oct. 2021
Curtis Joins The Appellate Project to Promote Appellate Practice to Diverse Law Students
Client Alert 15 Oct. 2021
Recent change in Dubai’s Arbitration Landscape.
News 20 Sep. 2021
Curtis Successfully Defends the Sultanate of Oman and Oman Aluminium Rolling Company LLC in U.S. Department of Commerce Trade Case
Client Alert 05 Oct. 2021
Proposed Legislative Changes to Federal Estate, Gift and Trust Taxation
Publications 22 Sep. 2021
Client Alert 24 Jun. 2021
U.S. Insight: Update on Virtual Notarization (Executive Order 202.7) During the COVID-19 (Coronavirus) Pandemic (Updated: June 24, 2021)
U.S. Insight: Update on Virtual Witnessing (New York Executive Order 202.14) During The COVID-19 (Coronavirus) Pandemic (Updated: June 24, 2021)
Publications May 2009
On May 4, 2009, the Obama Administration released a summary of its tax change proposals. On May 11, 2009, the Treasury Department issued the General Explanations of the Administration's Fiscal Year 2010 Revenue Proposals (the 'Green Book') to provide details of the Administration's tax change proposals. The proposed changes summarized below, if enacted, would have significant impacts on individuals with higher income and individuals who have interest in or authority over foreign financial accounts.
Sunset of the 2001 Tax Cuts. Several tax cuts enacted in 2001 will sunset after 2010. The Obama Administration proposed to allow the tax cuts to expire as scheduled and permanently extend the prior tax provisions affected by those tax cuts. For example:
Reporting of Foreign Financial Accounts. The Obama Administration's proposal would seek to strenghthen the information reporting obligations regarding foreign financial accounts. Under current law, U.S. persons who have an interest in or authority over one or more foreign financial accounts must report that interest on a Report of Foreign Bank and Financial Account ('FBAR') for each year during which the aggregate value of all such accounts exceeds $10,000. U.S. persons who directly or indirectly own more than 50% of a corporation, partnership, or trust that owns a foreign financial account are also required to file the FBAR. The proposal would require reporting on income tax returns any transfer to or from a foreign financial account, as well as disclosing on income tax returns certain information if the taxpayer must file an FBAR. The proposal would also establish certain evidentiary presumptions when the taxpayer fails to file the FBARs.
The Obama Administration's proposals described in the Green Book are far-reaching. It is difficult to predict what measures would eventually be enacted as proposed by the Administration.
To ensure compliance with requirements imposed by the IRS, we inform you that, unless explicitly provided otherwise, any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used, and cannot be used, for the purpose of (i) avoiding penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.
Marco A. Blanco
Eduardo A. Cukier