Earlier today (January 6, 2011), the Internal Revenue Service issued new proposed regulations which, if finalized, will require annual reporting of interest paid on deposits maintained by nonresident aliens at U.S. offices of certain financial institutions. These new proposed regulations replace ones that were issued in August 2002 (the “2002 Proposed Regs”), which themselves replaced […]
OFAC Issues Final Rule to Amend the Cuban Asset Control Regulations
Yesterday, the Department of Treasury’s Office of Foreign Assets Control (“OFAC”) issued a final rule (“Final Rule”) amending the Cuban Assets Control Regulations (31 CFR Part 515) (“Cuba Regulations”) to implement policy changes announced by President Obama on January 14, 2011, designed to increase people-to-people contact, support civil society in Cuba, enhance the free flow […]
USCIS Reaches FY 2011 H-1B Cap
On January 27, 2011, U.S. Citizenship and Immigration Services (“USCIS”) announced that it had reached the number of the statutory cap of H-1B Petitions for fiscal year (“FY 2011″) on January 26, 2011. Consequently, January 26, 2011 is the final receipt date for new H-1B specialty occupation petitions requesting an employment start date in FY […]
Required Use of E-Verify by Florida Contractors
Whether you are an in-state or out-of-state employer who contracts with Florida state agencies, or have been merely following the recent trend of states asserting themselves into the Immigration Reform Debate in the absence of Federal Comprehensive Immigration Reform, it is important to note that immediately after being sworn-in as Florida’s 45th Governor, Rick Scott, issued Executive […]
Estate Planning under the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010
As you are most likely aware, this past December Congress passed and the President signed into law legislation extending the “Bush Tax Cuts” for two years. The 2010 Tax Act contained significant changes to the estate, gift, and generation-skipping transfer (“GST”) tax rules for 2011 and 2012. We are writing this alert to advise you […]
FinCEN Issues Advisory: Risks with Jurisdictions Identified by FATF as Having Strategic Deficiencies in Their AML/CTF Regimes
On November 18, 2010, the Financial CrimesEnforcement Network (“FinCEN”), issued an advisory(“Advisory”) to inform banks and other financialinstitutions operating in the United States of the risksassociated with jurisdictions identified by the FinancialAction Task Force (“FATF”) on October 22, 2010(“Public Statement”), as having strategic deficienciesin their anti-money laudenring (“AML”) and counterterroristfinancing (“CFT”) regimes. In the Public […]
FinCEN Releases Final Rule to Clarify and Strengthen the Scope of SAR Confidentiality
Yesterday, the Financial Crimes Enforcement Network (“FinCEN”) released a final rule (“Final Rule”) to amend the Bank Secrecy Act (“BSA”) regulations regarding the confidentiality of suspicious activity reports (“SARs”) and to expand the ability of certain financial institutions to share SAR information with most affiliates. The Final Rule: (i) clarifies the scope of the statutory […]
Immigration-Related Employment Discrimination, Still an Issue?
U.S. Immigration and Customs Enforcement’s (“ICE”) highly visible enforcement efforts regarding employment eligibility verification over the last several years have successfully injected the terms “I-9 audits,” “Notices of Inspection (NOIs)” “E-Verify” and “IMAGE best practices” into the everyday vocabulary of business owners and their human resources personnel. Two recent press releases describing settlements between well-known […]
OFAC Issues the North Korea Sanctions Regulations
On November 3, 2010, the Office of Foreign Assets Control (“OFAC”) announced that it issued the North Korea Sanctions Regulations (“Final Rule”) to implement Executive Order 13466 of June 26, 2008 (“Executive Order 13466”) and Executive Order 13551 of August 30, 2010 (“Executive Order 13551”) (collectively, the “Executive Orders”). Executive Order 13466, among others, blocks […]
Important Voting Rules for Employers Regarding Your Employees’ Rights
This Tuesday, November 2, is election day across the country. It is important to note that most states have election laws in place to protect an employee’s right to vote without reprimand from their employer. As such, Florida law imposes restrictions and penalties against employers to protect employees’ right to vote. Specifically, it is illegal […]