A Conversation with Rajiv Gupta on Asia Restructurings
What Are the Drastic Ramifications of the New York State Anti-Money Laundering Actions and Penalty Enforcement?
Now, More than Ever, Taxpayers with Lingering Offshore Tax Non-Compliance Must Seek Professional Assistance - On November 20, 2018, the Internal Revenue Service (“the Service”) released a memorandum containing important...more
The terms FDAP (Fixed, Determinable Annual and Periodical Income) and ECI (Effectively Connected Income) are expansive terms. They are the backbone behind the tax withholding, and reporting requirements imposed on US Banks...more
First, former acting IRS Commissioner Steven Miller speaks out against FATCA and suggests that the benefits of the new information reporting regime imposed by FATCA may not outweigh its costs. An article published by...more
The Report of Foreign Bank and Financial Accounts (FBAR) can no longer be filed on TDF 90-22.1, and must be e-filed on Form 114. This alert summarizes developments involving FBAR e-filing and signature authority. They are...more
In response to taxpayer concerns about the practicality of meeting certain FATCA compliance timeline dates, the IRS, in Notice 2013-43 issued today, has extended some of those dates and made certain conforming changes. ...more
On January 18, the Treasury Department issued final regulations under the Foreign Account Tax Compliance Act (FATCA). The final regulations incorporate the FATCA guidance that the Internal Revenue Service (IRS) has issued...more