BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement
On December 13, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) addressing various aspects of the withholding...more
The Internal Revenue Service has released an updated version of its “FATCA Online Registration User Guide.” The updates primarily address the newly-released FFI agreement renewal function, which is now available on the IRS...more
FATCA is Chapter 4 of the Internal Revenue Code (IRC). It conscripts Foreign Financial Institutions (FFIs) to act as reporting and withholding agents for the U.S. Government. To enforce its conscription, it contains a...more
Following its publication on December 30, 2016, of an updated FFI agreement, the Internal Revenue Service has published a reminder to financial institutions about renewing their FFI agreement. All financial institutions that...more
The Luxembourg government has brought to Parliament a bill of law transposing UCITS V into Luxembourg’s UCI Law and AIFM Law. Further, the Luxembourg CSSF published a new version of its AIFMD Frequently Asked Questions, among...more
Global tax enforcement is the number one priority of the U.S. authorities, and they are using their resources and tools in unprecedented ways to ensure that those who intentionally evade taxes are identified and brought to...more
Foreign asset reporting requirements are nothing new. US taxpayers have long been required to report worldwide income, and the FBAR filing requirements have been around since the 1970s. ...more
Following last month’s announcement by the Saudi Arabian Capital Market Authority (the CMA) of its proposal to permit participation by qualified financial institutions directly on the Kingdom’s stock exchange (the Tadawul),...more
You have implemented FATCA; what comes next? Will your company be the next witness in a US tax investigation? Financial institutions around the world must now prepare to respond to anticipated inquiries and investigations as...more