Foreign Account Tax Compliance Act

The Foreign Account Tax Compliance Act is a United States federal statute enacted in 2010 as part of the Hiring Incentives to Restore Employment Act (HIRE Act). FATCA aims to improve compliance of U.S. taxpayers... more +
The Foreign Account Tax Compliance Act is a United States federal statute enacted in 2010 as part of the Hiring Incentives to Restore Employment Act (HIRE Act). FATCA aims to improve compliance of U.S. taxpayers by capturing tax revenue related to foreign assets and off-shore accounts.  less -
News & Analysis as of

Enforcement of Foreign Tax Claims

In many cases we have handled the taxpayers were dual nationals who have not only failed to adequately disclose and report foreign bank account and income to the IRS, but have also failed to report to the other country. This...more

Why are Americans Working Abroad Giving Up Citizenship?

Many Americans working abroad are renouncing their citizenship because of tax requirements imposed by U.S. tax laws. For Illinois residents employed overseas, an immigration lawyer in Chicago can explain tax laws that have an...more

New Tax Information Exchange Agreement Between the United States and Argentina

The governments of Argentina and the United States signed on December 23rd, 2016, a new tax information exchange agreement (“TIEA”). Jack Lew, U.S. Treasury Secretary, stated that the TIEA will allow for important...more

Bankers, Do your US Clients tell you everything that you need to know?

Given the information publicly revealed by “Panama Papers”, and recent IRS reminders to out-of-compliance US Taxpayers to come into full compliance with their federal tax obligations, it is critical that Bankers and Financial...more

The High Cost of Being Noncompliant with the Internal Revenue Code

The IRS currently offers the following five programs for noncompliant taxpayers: (i) the Offshore Voluntary Disclosure Program (OVDP), (ii) Streamlined Domestic Offshore Procedures, (iii) Streamlined Foreign Offshore...more

US FATCA: Deadline to Register Sponsored Entities Approaching

Sponsoring entities should evaluate which of their sponsored entities should be registered via the IRS registration portal....more

¿Sabe usted por qué y cómo entrar en el Programa de Divulgación Voluntaria de Cuentas en el Extranjero (OVDP)?

A través del Programa de Divulgación Voluntaria de Cuentas en el Extranjero (OVDP – Offshore Voluntary Disclosure Program), el IRS permite a los Contribuyentes que no están en cumplimiento intentionalmente revelar las cuentas...more

Do you know why and how to make an Offshore Voluntary Disclosure?

Through its Offshore Voluntary Disclosure Program (OVDP), IRS permits noncompliant taxpayers to disclose Willfully unreported offshore accounts and related income. The “key” word for OVDP is Willful. Unlike the Streamlined...more

Cuando FATCA y los Programas de Amnistía Fiscal se cruzan, ¿será demasiado tarde para los contribuyentes Estadounidenses?

Instituciones Financieras extranjeras (FFIs) y las autoridades fiscales de los países anfitriones le han proporcionado al IRS con una segunda ronda de informes de información sobre cuentas financieras mantenidas por los...more

When FATCA and Tax Amnesty Programs intersect, will it be too late for US Taxpayers?

Foreign Financial Institutions (FFIs) and host country tax authorities have provided IRS with a second round of information reports on financial accounts held by US Taxpayers. This exchange of information is automated and...more

FATCA: Final Deadline to Obtain a GIIN for Sponsored Investment Funds

Key Points - - Transitional relief for non-U.S. investment funds that have been previously permitted to provide only a sponsor’s GIIN to avoid incurring FATCA withholding ends on December 31, 2016. - U.S....more

FATCA and CRS: 2016 Year End Reminders and a Look Ahead to 2017

As 2016 comes to a close, U.S. FATCA is almost fully phased-in, U.K. FATCA is being phased-out and the Common Reporting Standard (“CRS”) is nearing the first anniversary of its effective date. What began as a concept in 2010...more

Tax Evasion - Nowhere Left to Hide

Global tax evasion remains a major problem for governments around the world. At a time when virtually all of the governments from the world’s major economies seek additional revenue, the attractiveness to taxpayers of...more

If you are an “Expat”, or thinking about “Expatriating”, think about this!

Thinking about giving up your US citizenship pending the results of the Presidential election in November 2016? Concerned because you have been an “Expat” for a long time and have not filed US Tax returns? Just realized that...more

Tax Alert for Foreign Investors Looking at U.S. Investments

Pre-immigration and Non-U.S. Resident Planning - It does not matter whether foreign individuals are investing in U.S. property and hoping to become residents in the U.S., or are planning to invest in U.S property...more

Pre-immigration and Non-U.S. Resident Planning

Foreign individuals who intend to permanently reside in the U.S., or do not intend to reside in the U.S. but intend to own U.S. property, need considerable legal and tax planning. The definition of “U.S. property” for...more

Tax Court Flexes Its Debt-Equity Muscle on “Unrelated” Parties

The Tax Court, in American Metallurgical Coal Co., TC Memo 2016-139, recently held that financing of a sale of partnership interests by a foreign seller to a U.S. buyer was not debt, but equity. The court found that the...more

Sonhos Interrompidos - Como uma não conformidade tributária pode destruir o Sonho Americano de imigrantes não registrados - Parte...

Panorama - A Parte I desta série teve enfoque no pesadelo e problema imprevisto de declarações de impostos não apresentadas para imigrantes não registrados. As consequências de "empurrar o problema com a barriga"...more

Cayman Islands FATCA Compliance Deadlines Extended Again

The Cayman Islands announced the further extension of the 2016 registration and reporting deadlines for U.S. FATCA and U.K. FATCA (also known as U.K. CDOT), as follows...more

Anti-BEPS Ukraine style: de-offshorization initiative launches

Leakage of profits to offshore locations and tax evasion through aggressive planning has always been a hot topic in Ukraine. However, it must be said that, with the exception of the introduction of transfer pricing rules in...more

Broken Dreams - How Tax Non-Compliance Can Destroy the American Dream of Undocumented Immigrants - Part 2

Part I of this series focused on the unforeseen nightmare and problem of unfiled tax returns for undocumented immigrants. The consequences of “kicking the can down the road”, will have significant legal and financial...more

IRS Floats Updated Qualified Intermediary Agreement

In recent Notice 2016-42, the IRS has proposed a new qualified intermediary (QI) agreement. The current QI agreement, set forth in Rev. Proc. 2014-39 (“the 2014 QI agreement”), expires December 31, 2016. The IRS expects to...more

¡Primera Convicción de FATCA!

El 9 de Mayo del 2016, el Departamento de Justicia (DOJ) anunció su primera convicción usando FATCA. Parece ser el principio de procesos penales por el DOJ contra violaciones aparentes o presuntas de los requisitos de...more

¿Sabía usted que el IRS puede presentar una "Declaración de Impuestos Sustituta” basado en la información del Reporte FATCA?

¿Sabía usted que bajo el Código de Rentas Internas EE.UU, Sección 6620, si un contribuyente no presenta a tiempo la declaración de impuestos de los EE.UU., el IRS está autorizado a preparar y presentar una declaración de...more

Did You Know That the IRS May File a “Substitute for Return” from FATCA Report Account Holder Information?

Did you know that, under Internal Revenue Code, Section 6620, if a taxpayer does not timely file a U.S. tax return, the IRS is authorized to prepare and file a U.S. tax return for that taxpayer based on the knowledge that it...more

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