Sherwin P. Simmons, II

Sherwin P. Simmons, II

Akerman LLP

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2014 Foreign Financial Account Reporting Requirements

U.S. citizens or residents who owned, directly or indirectly through an entity, beneficially or who had power of attorney/signature authority over one or more foreign financial accounts with an aggregate value exceeding...more

6/5/2015 - Electronic Filing FBAR FinCEN Foreign Financial Accounts Income Taxes Reporting Requirements Tax Penalties Tax Returns

DOJ Announces First Non-Prosecution Agreement Under the Swiss Bank Program

On March 30, 2015, the U.S. Department of Justice (DOJ) announced that it reached the first non-prosecution agreement under the Swiss bank program with BSI, S.A. (BSI). BSI, one of Switzerland's ten largest banks, has agreed...more

4/16/2015 - BSI SA DOJ FATCA FFI Foreign Bank Accounts Foreign Banks Non-Prosecution Agreements OVDP Popular Swiss Banks Tax Evasion

IRS Modifies Offshore Voluntary Disclosure Program and Expands Streamlined Procedures

On June 18, 2014, the Internal Revenue Service (IRS) announced major changes to its 2012 Offshore Voluntary Disclosure Program (OVDP) and streamlined procedures. The modifications provide new options to help both taxpayers...more

6/23/2014 - Compliance FATCA IRS Offshore Funds OVDP Reporting Requirements

Florida Doctor Sentenced for Defrauding the IRS

On May 9, 2014, a Florida doctor was sentenced to serve two years in prison and three years supervised release for conspiring to defraud the Internal Revenue Service (IRS). The doctor was found guilty of concealing millions...more

6/12/2014 - Fraud IRS Physicians Tax Evasion Tax Fraud

2013 Foreign Financial Account Reporting Requirements

U.S. citizens or residents who owned, directly or indirectly through an entity, beneficially, or who had power of attorney/signature authority over one or more foreign financial accounts with an aggregate value exceeding...more

6/3/2014 - FBAR FinCEN International Tax Issues IRS Offshore Funds Reporting Requirements

Treasury Delays FATCA Deadlines by Six Months

On July 12, the Treasury Department issued Notice 2013-43, which provides a revised timeline for the Foreign Account Tax Compliance Act (FATCA). The FATCA withholding and reporting requirements will be delayed six months...more

7/26/2013 - Deadlines Delays FATCA FFI GIIN IGAs PFFI Reporting Requirements U.S. Treasury

2012 Foreign Financial Account Reporting Requirements -- Important Filing Deadline on June 30, 2013

U.S. citizens or residents who owned, directly or indirectly through an entity, or who had power of attorney/signature authority over one or more foreign financial accounts with an aggregate value exceeding $10,000 at ANY...more

6/18/2013 - FBAR Filing Deadlines Foreign Financial Accounts Forms Reporting Requirements Tax Returns

I.R.S. Issues FATCA Final Regulations

On January 17, 2013, the IRS released final regulations for the Foreign Account Tax Compliance Act ("FATCA") to be effective on January 28, 2013. Enacted by Congress in 2010, FATCA targets non-compliant U.S. taxpayers using...more

1/31/2013 - FATCA Foreign Banks Foreign Financial Accounts IRS

International Tax Impact of American Taxpayer Relief Act

On January 1, 2013, the Senate passed the American Taxpayer Relief Act, H.R. 8 (the "Bill"), by a vote of 89 to 8. Later that same day, the House of Representatives approved the Bill by a vote of 257 to 167. On January 2,...more

1/17/2013 - American Taxpayer Relief Act Capital Gains Controlled Foreign Corporations Fiscal Cliff JOBS Act Qualified Foreign Corporation

FATCA Model II Agreement Released

The U.S. Department of Treasury ("Treasury") recently released its second model agreement (the "Model II Agreement") for countries to implement the Foreign Account Tax Compliance Act ("FATCA"). FATCA requires foreign...more

12/6/2012 - FATCA FFI IRS U.S. Treasury

United States Signs Bilateral Agreements to Implement FATCA with Denmark and Mexico

The United States has entered into its second and third bilateral agreements regarding the implementation of FATCA with Denmark and Mexico, respectively. FATCA was enacted in 2010 as part of the Hiring Incentives to Restore...more

12/6/2012 - FATCA Foreign Investment HIRE Act

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