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American Jobs Plan & Made in America Tax Plan—Summary of Certain Key Tax Components

On Wednesday March 31, 2021, President Joseph R. Biden announced the American Jobs Plan and Made in America Tax Plan, designed to provide dramatic improvements to U.S. infrastructure writ large. The American Jobs Plan will focus on physical infrastructure, climate change, domestic manufacturing, research and development (R&D), and home health care services. The White House fact sheet outlining the plans can be found here but the proposed statutory language for the plans have not yet been released. The plan proposes funding the initiatives from measures including (i) increasing the corporate tax rate from 21% to 28%, (ii) creating a 15% minimum tax on global book income, (iii) increasing the minimum effective tax rate on GILTI from 10.5% to 21%, (iv) moving towards a global minimum tax and preventing profit-stripping from U.S., (v) modifying deductions to incentivize on-shoring, (vi) eliminating subsidies for fossil fuels, and (vii) increasing tax enforcement.

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IRS Extends Certain FBAR Filing Deadlines to June 30, 2010


Time to Read: 1 minutes Practices: Tax, Hedge Funds

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With limited exceptions, each U.S. person with either a financial interest in or signature (or comparable) authority over one or more foreign financial accounts is required to report that relationship annually to the Internal Revenue Service (IRS) on U.S. Treasury Form TD F 90-22.1, "Report of Foreign Bank and Financial Accounts" (FBAR). Recently, there has been significant controversy related to the FBAR filing requirements for (i) persons with signature authority over, but no financial interest in, a foreign financial account, and (ii) persons with a financial interest in, or signature authority over, a foreign commingled fund. Previously, the IRS provided an extension of FBAR filing deadlines in certain circumstances to September 23, 2009. (See also our June 19 alert relating to the FBAR.)

IRS Notice 2009-62, released earlier today, extends until June 30, 2010 the FBAR filing deadlines for the 2008 and earlier calendar years for (i) persons with signature authority over, but no financial interest in, a foreign financial account, and (ii) persons with a financial interest in, or signature authority over, a foreign commingled fund. Notice 2009-62 also indicates that the U.S. Department of the Treasury intends to issue regulations clarifying the FBAR filing requirements as applicable to persons in both of the foregoing categories, and solicits comments related thereto.

We are continuing to review Notice 2009-62 and related authority in order to provide detailed guidance for particular client situations. If you would like to discuss Notice 2009-62 or other issues concerning FBAR filings, please contact your usual Ropes & Gray lawyer.

Circular 230 Disclosure: To ensure compliance with Treasury Department regulations, we inform you that any U.S. tax advice contained in this communication (including any attachments) was not intended or written to be used, and cannot be used, for the purpose of avoiding U.S. tax-related penalties or promoting, marketing or recommending to another party any tax-related matters addressed herein.

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