International Trade Finance & Banking Tax

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Banking & Financial Services E-Note

In This Issue: - 70 Countries Agree to Share Bank Information in Tax Evasion Probe - Financial Industry Pushes Back Against Proposed ERISA Requirements - Federal Reserve Proposes Tougher Stress Tests for...more

3 Red Lights And 3 Green Lights For Non-US Investors In US Real Estate: Tax Challenges And Solutions

Investment in US real estate by non-US investors is increasing. Non-US investors acquired almost $23 billion in US real estate, representing a 9% increase over 2012 and accounting for 13% of all real estate transactions in...more

The IRS’ New 2014 Offshore Voluntary Disclosure Procedures (Part 1)

Last weekend I published the introduction to my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures. Below is Part 1 of his 6 part...more

Offshore Asset Reporting: Rules, Enforcement, and Options for Compliance

In this presentation: -Overview: Reporting Regimes for Offshore Assets -Department of the Treasury: Report of Foreign Bank and Financial Accounts (FBAR) -Form 8938, Statement of Specified Foreign...more

Introduction of the Exploration Development Incentive

In the 2014 Budget, the Federal Government announced that it would introduce Exploration Development Incentive (EDI) tax credits to encourage and stimulate growth in the junior mining industry. This is a simpler approach to...more

German Federal Government Plans Tax Exemption of INVEST – Subsidy for Venture Capital

The German Federal Government has given an important insight to its plans and future measures regarding taxation of the start-up- and VC-ecosystem in Germany by officially answer to a parliamentary request by several members...more

M&A Update | Inversions: The View from Ireland

On June 25, 2014, Ireland’s Taoiseach (Prime Minister) Enda Kenny and Minister for Finance Michael Noonan, among others, met with Cadwalader Chairman-elect and Corporate Group Co-Chair James C. Woolery in Dublin regarding...more

Congress Returns from July 4th Recess - What to Expect in the Coming Months

Although the 113th Congress continues to see a dearth of legislation seeing final approval, over the past six months, Congress has managed to finalize Fiscal Year 2014 appropriations; address the Sustainable Growth Rate...more

IRS Announces Changes to Its Offshore Voluntary Disclosure and Streamlined Procedures

On June 18, 2014, the IRS announced a number of significant changes to its Offshore Voluntary Disclosure Program (OVDP) and 2012 streamlined procedure for nonresidents and the addition of a streamlined procedure for U.S....more

Orrick's Derivatives in Review - July 2014

Extension of Certain Dodd-Frank No-Action Relief - The CFTC recently established a phased compliance timeline for the implementation of the execution requirement currently applicable to certain interest rate swaps and...more

Foreign Tax-Exempt Organizations Exempt from Withholding Tax

Investment funds, including private equity funds, often receive capital contributions from tax-exempt organizations. These tax-exempt institutions may include U.S. and foreign pension funds, as well as U.S. and foreign...more

BVI Government signs Model 1B IGA in relation to FATCA

The BVI Government has signed a Model 1B (non-reciprocal) Intergovernmental Agreement (IGA) in relation to the US Foreign Account Tax Compliance Act (FATCA), it was announced on 30 June 2014....more

International Tax News - June 2014

NEW FOR SUPPLIERS OF DIGITAL CONTENT AND INTANGIBLES: DLA PIPER’S GLOBAL VAT GUIDE - Starting January 1, 2015, EU VAT rules for suppliers of digital content, telecommunications and broadcasting services are changing....more

Significant Revisions to the IRS Offshore Voluntary Disclosure Program

The existing OVDP has been in place since March 2009. The program allows a taxpayer to voluntarily come into compliance with US tax reporting obligations and pay a reduced civil penalty rather than facing either greater...more

After All the Preparation, It’s Finally Here: FATCA Becomes Effective July 1, 2014

More than four years after Congress enacted the Hiring Incentives to Restore Employment Act of 2010, Pub. L. 111-147, which added the Foreign Account Tax Compliance Act (FATCA) provisions to the Internal Revenue Code, FATCA...more

China and U.S. Conclude FATCA IGA In Substance

On June 26, 2014, China and the United States agreed on a Model 1 FATCA IGA. The Treasury did not say whether the agreement would be reciprocal. The IGA comes just in time for the July 1 start of 30 percent withholding on...more

Traps Within the new Streamline Offshore Account Disclosure Program

The new Streamlined Filing Compliance Procedures (the Streamline Procedures) go into effect July 1, 2014. Under the terms of the procedures some taxpayers will suffer no penalty for failure to timely file FBARs, (in the case...more

Offshore Tax Enforcement Update: IRS Unveils Major Changes to Voluntary Disclosure Program

Since the 1970s, U.S. taxpayers with foreign banks accounts have been required to annually report their foreign bank account information to the Department of Treasury on a Report of Foreign Bank and Financial Accounts...more

IRS Broadens Offshore Amnesty Program

Over the last several years, the Internal Revenue Service (IRS) has focused its efforts on enforcement of U.S. laws with respect to offshore assets held by U.S. citizens and residents, including their tax payment and...more

IRS Changes the Streamlined Filing Compliance Procedures and Offshore Voluntary Disclosure Program (OVDP) - Determining Your Most...

The IRS announced substantial changes to both the Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer Taxpayers and the Offshore Voluntary Disclosure Program (OVDP) on June 18, 2014....more

A Closer Look Into FBAR Late Payment And Interest Penalties Through The Zwerner Settlement – What Were The Penaties And Interest?...

While much about the Zwerner case (U.S. v. Zwerner, Case No. 13-22082-CIV, So. Dist. Fl.) has been discussed regarding the FBAR penalties, there has not been much attention paid to the 6% late payment penalty and interest...more

"Latest Swiss Cross-Border Tax Investigation Reflects Wider US Enforcement Agenda"

Authorities in the U.S. continue to crack down on foreign financial institutions that have allegedly aided U.S. taxpayers in evading their tax obligations. On May 19, 2014, Credit Suisse AG pled guilty to conspiracy to aid...more

Former Head of DOJ Tax Division Warns Taxpayers to Think Twice Before Choosing New Streamlined Procedures

Former DOJ Tax Division AAG Kathy Keneally warned on June 24, 2014, that taxpayers should think carefully before signing a certification of non-willfulness and entering the IRS’s new Streamlined Filing Compliance Procedures....more

Update on the EU's Proposed Financial Transactions Tax

The Court of Justice of the European Union (CJEU) recently issued a decision rejecting the UK government’s initial legal challenge against the proposed introduction of a financial transactions tax (FTT) in Europe. The...more

Sweden proposes new system for corporate taxation: a redistribution of tax payments in the business sector

A Swedish government committee mandated to analyze the Swedish corporate tax system - including the need for a more comprehensive approach to the overall deductibility of interest expenses, as well as the strengthening of the...more

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