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Offshore Accounts? IRS is Watching

If you have unreported income from offshore accounts, now may be the best time to come forward and report those earnings; otherwise, you may be susceptible to criminal prosecution. The IRS initially began this...more

Deadlines Coming for Multinationals’ Retirement Plans and U.S. Taxpayers with Foreign Financial Interests

In 2010, the U.S. enacted a sweeping change in enforcement of its tax laws on foreign financial interests, the Foreign Account Tax Compliance Act (FATCA). The main thrust of the act is to penalize foreign financial...more

Doing Business in Latin America and The Caribbean: Columbia

Colombia is located in the northernmost part of South America. Its population is estimated at over 45 million people, with at least 10 million living in the capital city of Bogotá. Colombia’s main language is...more

Focus on Tax Controversy and Litigation - Supreme Court Decides Woods v. Commissioner, Holds for IRS on Jurisdictional and...

In this issue: - US Supreme Court Imposes Valuation-Misstatement Penalty in TEFRA Proceeding - Southern District of New York holds Cooperation with Government Waives Attorney-Client Privilege - IRS Issues...more

Initial FATCA Registration/Withholding Dates Draw Near

Foreign financial institutions, such as offshore funds, should register with the IRS by May 5 and review new and revised IRS forms. The July 1 start date for Foreign Account Tax Compliance Act (FATCA) withholding on...more

IRS Offers FATCA Relief, Extending Registration Deadline and Expanding Intergovernmental Agreement List

On April 2, 2014, the U.S. Internal Revenue Service (IRS) issued Announcement 2014-17 (the Announcement), which provides certain FATCA relief. The Announcement extends from April 25, 2014 to May 5, 2014 the deadline by which...more

Doing Business in Latin America and The Caribbean: Chili

Chile’s business environment is the result of a policy-driven strategy that has focused on building sound macroeconomic fundamentals and strong institutions, promoting competition and international integration, and creating a...more

Blame It on the Bossa Nova! A One Note Samba for Inbound Real Estate in the U.S

As an undergraduate at West Point, I was a Spanish and Portuguese major. My Brazilian “thing” had already started a decade earlier as a ten year old growing up in the Panama Canal Zone seeing Pele play for his Brazilian team...more

Wealth Management Update - April 2014

April Interest Rates Hold Steady for GRATs, Sales to Defective Grantor Trusts, and Intra-Family Loans. The April applicable federal rate ("AFR") for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more

IRS Says Bitcoin Isn’t Money

On March 25, 2014 the IRS issued Notice 2014-21, which describes how the IRS will interpret existing general tax principles to apply to transactions using “virtual currencies” such as Bitcoin. This Notice is the most recent...more

Doing Business in Latin America and The Caribbean: Cayman Islands

The Cayman Islands are located in the western Caribbean Sea about 480 miles south of Miami and 180 miles northwest of Jamaica. Of the three islands, Grand Cayman is the largest with an area of 76 square miles. The islands of...more

FATCA: Initial Registration Deadline Extended

On April 2, 2014, the IRS announced that foreign entities that must be FATCA-compliant by July 1, 2014 now have until June 3, 2014 to register with the IRS (as opposed to the previous April 25, 2014 registration deadline)....more

Mexican Energy Reform Progress Report - Two Steps Forward, One Step Back

Finalization of Mexico’s energy reforms is accelerating and specific foreign investment opportunities are emerging, but detailed “Secondary Legislation” will likely be delayed to late April or a special congressional session...more

IRS: Bitcoin Not A Currency For Tax Purposes

As expected, the U.S. Internal Revenue Service has provided some guidance on the U.S. tax treatment of Bitcoin. In Notice 2014-21 (March 25, 2014), the IRS stated that Bitcoin is property and not currency for tax...more

Offshore Disclosure: What Needs To Be Disclosed? A Checklist

The following is a list of questions that should lead to the discovery of offshore assets, whether properly reported or not. If you answer yes to any of these questions, then you may have filing obligations and should seek...more

IRS Extends FATCA Registration Deadline to May 5, 2014

HIGHLIGHTS: - Foreign financial institutions must perform due diligence to identify their U.S.-owned accounts and report them to the IRS, as well as act as a withholding agent for payments to other foreign entities....more

My, What Long Arms You Have, Uncle

Here’s a visual: Uncle Sam extending his arms around the world, reaching out for his citizens, wherever they may be. He may resemble a candy-striped Gumby, with disproportionately long rubbery arms spanning the globe. The...more

BVI Financial Institutions now able to register with the IRS for a GINN

In a welcome announcement made on 2 April 2014, the US Internal Revenue Service (IRS) made provision for Financial Institutions in jurisdictions that have already reached an "agreement in substance" on the terms of a Model 1...more

Doing Business in Latin America and The Caribbean: Brazil

With more than 196 million inhabitants and over 8.5 million square kilometers, Brazil is the largest country and economy in Latin America (its GNP in 2011 was roughly USD2.07 trillion). It is a federative republic, consisting...more

Battuta D'arresto Per La Voluntary Disclosure

Come annunciato, l'articolo 1 del decreto legge 28 gennaio 2014, n. 4 (pubblicato in G.U. n. 23 del 29 gennaio 2014 – di seguito "Decreto") in materia di "Voluntary Disclosure" o "Collaborazione Volontaria" per il rientro dei...more

Taxing Non-Residents on Capital Gains from UK Residential Property – UK Government Consults on New Rules

The UK does not generally impose tax on capital gains of non-UK residents in relation to real estate properties in the UK. However, the Government has announced that tax will be imposed on future capital gains made by non-UK...more

Cuba Practice Update

Cuban Parliament Passes New Foreign Investment Law - On March 29, 2014, Cuba's 576-member National Assembly unanimously approved a measure designed to encourage foreigners to invest more than $2 billion a year in the...more

Doing Business in Latin America and The Caribbean: Bolivia

Bolivia is a country with amazing natural beauty and a diverse landscape, sheltering a fourth of the world’s greatest biodiversity. Bolivia’s riches also include raw material, industrialized material and of course, tourism....more

New IRS Guidance Offers Insight Regarding Covered Transactions Under the Transaction Cost Regulations

When the IRS released the transaction cost regulations of Treas. Reg. 1.263(a)-5, a new term was created: “covered transaction.” Unlike the treatment of a covered transaction in a tax shelter context, which is generally...more

U.S. Signs FATCA IGA with Luxembourg

On March 28, 2014, the U.S. signed a FATCA IGA with Luxembourg. Under the IGA, banks and other financial institutions in Luxembourg will report information about eligible U.S. customers’ offshore accounts to the Luxembourg...more

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