All U.S. citizens and permanent residents are required to annually file a U.S. income tax return reporting their worldwide income from all sources. Additionally, U.S. citizens and permanent who have an interest in or signatory authority over foreign bank and financial accounts holding $10,000 or more at any time during the year must independently identify and report these interests to the U.S. Department of Treasury's Financial Crimes Enforcement Network ("FinCEN"). This annual disclosure must be filed electronically using Form 114, Report of Foreign Bank and Financial ...
On December 29, 2016, the U.S. Department of Labor (the "DOL") released Interpretive Bulletin 2016-1 ("IB 2016-1") relating to the voting of proxies on securities held in employee benefit plans. IB 2016-1 withdraws the current Interpretive Bulletin dealing with the voting of such proxies (Interpretive Bulletin 2008-2 or "IB 2008-2") and reinstates the prior Interpretive Bulletin dealing with the proxy voting (Interpretive Bulletin 94-2) with updates.
In the background to IB 2016-1, the DOL noted that IB 2008-2 "has been read by some stakeholders to articulate a general rule that ...