BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement
On January 17, 2013, the Internal Revenue Service (“IRS”) released final regulations (the “Final Regulations”) implementing the reporting and withholding provisions of the HIRE Act (commonly known as the Foreign Account Tax...more
The Internal Revenue Service has had success encouraging taxpayers with offshore accounts to disclose their foreign accounts and pay back taxes. In 2009 and 2011, the IRS announced the Offshore Voluntary Disclosure Program...more
In the wake of a series of scandals involving U.S. taxpayers sheltering their assets from the reach of the U.S. Internal Revenue Service (IRS), Congress enacted the Foreign Account Tax Compliance Act (FATCA) on 18 March 2010...more
On January 17, 2013, the U.S. Treasury Department (“U.S. Treasury”) and the Internal Revenue Service (“IRS”) released long-awaited final regulations on the Foreign Account Tax Compliance Act (“FATCA”). The final regulations...more
On July 26, 2012, the U.S. Department of Treasury released its first model intergovernmental agreement (IGA) implementing the information reporting and withholding tax provisions under the Foreign Account Tax Compliance Act...more
On July 26, 2012, the Treasury Department released two versions of a model intergovernmental agreement (model IGA) for government-to-government information sharing under the Foreign Account Tax Compliance Act (FATCA). One...more
The U.S. Treasury Department recently issued proposed regulations interpreting sections of the Internal Revenue Code (the Code) commonly referred to as the Foreign Account Tax Compliance Act (FATCA). The proposed regulations,...more
The U.S. Treasury Department (“Treasury”) and the Internal Revenue Service (“IRS”) on February 8, 2012 issued proposed regulations addressing the implementation of the Foreign Account Tax Compliance Act (“FATCA,” which was...more
The U.S. Department of the Treasury and the Internal Revenue Service recently issued proposed regulations under Sections 1471–1474 of the Internal Revenue Code. The proposed regulations provide updated guidance on information...more
Proposed Regulations under the Foreign Account Tax Compliance Act Issued February 8, 2012 On February 8, 2012, the U.S. Treasury Department and the Internal Revenue Service ("IRS") released widely anticipated proposed...more
In This Presentation: FATCA: Foreign Account Tax Compliance Act - History - Nuts and Bolts - Highlights of Proposed Regulations - Intergovernmental Agreement - Next Steps - Q&A Please see full...more
On February 8, 2012, the US Treasury Department (“US Treasury”) and the Internal Revenue Service (“IRS”) released long-awaited proposed regulations on the Foreign Account Tax Compliance Act (“FATCA”). The proposed regulations...more
On February 8, 2012, the U.S. Treasury and the Internal Revenue Service (the IRS) issued proposed regulations on the implementation of the withholding and due diligence provisions of the Foreign Account Tax Compliance Act...more
On February 8, 2012, Treasury and the IRS issued comprehensive proposed regulations (Proposed Regulations) that would, when finalized, implement the Foreign Account Tax Compliance Act (FATCA), which was enacted in March 2010....more