News 08 Jan. 2021
Curtis Adds Africa Insider and Corporate Partner Kalidou Gadio in the U.S.
News 18 Nov. 2020
Libya Obtains Historic Victory in Setting Aside of EUR452 Million Arbitral Award
News 15 Dec. 2020
Kazakhstan Secures US$1.9 Billion in Settlement of Arbitral Dispute
News 26 Feb. 2020
Curtis Secures Comprehensive Victory for the Republic of Kazakhstan’s Committee of Roads
Event 05 Jan. 2021
Partner Robert Honeywell participates in Fundación Fide panel on U.S. and Spanish Insolvency Systems
News 20 Dec. 2020
Curtis Counsel Fuad Zarbiyev Nominated for Membership in International Law Commission
Event 19 Jan. 2021
Partner Gabriela Alvarez Avila Participates in Instituto Peruano de Arbitraje’s Third International Women in Arbitration Conference
News 17 Dec. 2020
Partner Antonio Prida and Associate Irene Cuellar Publish Article on Mexico Potentially Incorporating The UNCITRAL Model Law and The Singapore Convention into National Legislation
Client Alert 13 Jan. 2021
The U.S. Court of Appeals for the Ninth Circuit Upholds Qatar’s Sovereign Immunity in Cyberespionage Case
Event 09 Jan. 2021
Partner Charles Howland Serves as Judge for the Stetson International Environmental Moot Court Competition
Client Alert 30 Dec. 2020
U.S. Insight: Update on Virtual Notarization (Executive Order 202.7) During the COVID-19 (Coronavirus) Pandemic (Updated: December 30, 2020)
U.S. Insight: Update on Virtual Witnessing (New York Executive Order 202.14) During The COVID-19 (Coronavirus) Pandemic (Updated: December 30, 2020)
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