Foreign Financial Accounts

News & Analysis as of

IRS Clarifies Requirements for Establishing Non-Willful Conduct in Offshore Disclosure Cases

Voluntary disclosure programs exist for taxpayers that are not in compliance with their tax and information reporting obligations with respect to foreign bank accounts and assets. The Internal Revenue Service (IRS) recently...more

FATCA – It’s Here, It’s Not Going To Be Delayed And Action May Be Needed By April 25, 2014. Is Your Fund Ready?

FATCA is the new form of 30% U.S. withholding tax that is applied to U.S. source income, such as interest and dividends paid by U.S. companies, starting as early as July 1, 2014 for payments made to non-U.S. entities that are...more

2012 Foreign Financial Account Reporting Requirements -- Important Filing Deadline on June 30, 2013

U.S. citizens or residents who owned, directly or indirectly through an entity, or who had power of attorney/signature authority over one or more foreign financial accounts with an aggregate value exceeding $10,000 at ANY...more

International Tax Planning for Businesses is Art and Politics

The recent Congressional hearings on taxation of multinational corporations drew a lot of focus on the low tax rates and low taxes paid (relative to revenue). Congress expressed outrage that the largest companies in the world...more

Eleventh Circuit Holds that Production of Foreign Bank Account Records May be Compelled in Criminal Investigation Under Required...

The Eleventh Circuit recently joined the Fifth, Seventh, and Ninth Circuits in holding that subpoenaed foreign financial records properly fall within the Required Records Exception to the Fifth Amendment privilege against...more

White Collar Watch - March 2013

In This Issue: - Eleventh Circuit Holds that Production of Foreign Bank Account Records May be Compelled in Criminal Investigation Under Required Records Exception to Fifth Amendment Privilege - Supreme Court...more

Highlights of Recently Released FATCA Regulations

On January 17, the Internal Revenue Service issued long-awaited final regulations (the Final Regulations) for implementing the Foreign Account Tax Compliance Act (FATCA) (the Final Regulations are contained in T.D. 9610). For...more

Significant Changes Made in Final FATCA Regulations

On January 17, 2013, the U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) released final regulations (the “Regulations”) implementing foreign account reporting provisions of the...more

I.R.S. Issues FATCA Final Regulations

On January 17, 2013, the IRS released final regulations for the Foreign Account Tax Compliance Act ("FATCA") to be effective on January 28, 2013. Enacted by Congress in 2010, FATCA targets non-compliant U.S. taxpayers using...more

FATCA Regulations Finally Arrive: A First Look

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

IRS Issues Final FATCA Regulations

On January 17, 2013 the Internal Revenue Service issued long-awaited final regulations that implement the Foreign Account Tax Compliance Act (FATCA), the new reporting and withholding tax regime that applies to foreign...more

Must You Produce Records of Offshore Accounts?

A Petition to the U.S.Supreme Court may result in the Court deciding whether a taxpayer who has a previously unreported foreign financial account must produce records of the account in a criminal proceeding in spite of the...more

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