Internal Revenue Service Foreign Account Tax Compliance Act

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
News & Analysis as of

FATCA Update: Treasury Clarifies Obligations of Participating FFIs to Report Pre-Existing Accounts

Earlier today, Treasury and the IRS issued yet another correcting amendment to the previously-issued regulations implementing the Foreign Account Tax Compliance Act (FATCA). FATCA become effective on July 1, 2014, and...more

Hong Kong Signs FATCA IGA

On November 13, 2014, Hong Kong announced that it had signed a Model 2 FATCA IGA. Under the agreement Hong Kong financial institutions will enter into separate FFI agreements with the IRS and will report information on U.S....more

U.S. Will Disclose Swiss Bank Information

The Department of Justice (DOJ) recently made demand of 106 Swiss banks for information and cooperation under the terms of proposed Non-prosecution agreements (NPA). Non-prosecution agreements were offered to Swiss banks in...more

FATCA Alert

In recent years, the United States has increased initiatives to counter tax evasion committed by U.S. persons who are not reporting and paying U.S. income tax on earnings derived from foreign financial assets. The Foreign...more

FATCA Notebook: Former IRS Chief, Taxpayer Advocate Criticize FATCA; Switzerland Moves Toward Greater Transparency

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

FATCA Update: Brazil Signs IGA with U.S. and Treasury Releases More Guidance

On September 24, 2014, the government of Brazil announced it had signed an intergovernmental agreement with the United States as part of its adoption of the requirements of the Foreign Account Tax Compliance Act (FATCA). The...more

IRS Issues FATCA Fraud Alert

As part of its continuing efforts to combat the serious problem of identity theft, the Internal Revenue Service warned today that fraudsters have expanded their widening schemes to obtain identity information to foreign...more

U.S. Tax Developments Affecting Financial Institutions and Products

Recent months have seen significant IRS and judicial developments affecting financial institutions and market participants, including new FATCA changes and proposed regulations on dividend equivalent payments under section...more

Beyond Switzerland: Preparing for the Fallout from FATCA and Other Global Transparency Initiatives

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

Tax Talk -- Volume 7, No. 2 -- July 2014

In This Issue: - As FATCA Begins, IRS Rolls out Withholding Forms, Increases IGA Count - IRS Issues Final Circular 230 Rules Simplifying Written Tax Advice Requirements - Mortgage CCA Raises More...more

Capital Thinking: Tax and Retirement

LEGISLATIVE ACTIVITY - Senate to Vote on Highway funding bill - This week, the Senate is expected to vote on H.R. 5021, the Highway and Transportation Funding Act of 2014, which recently passed the House by a...more

Part 2 - The IRS’ New 2014 Offshore Volunteer Disclosure Procedures

Below is Part 2 of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures. To view this Part, and all prior parts, in PDF format...more

Offshore Asset Reporting: Rules, Enforcement, and Options for Compliance

In this presentation: -Overview: Reporting Regimes for Offshore Assets -Department of the Treasury: Report of Foreign Bank and Financial Accounts (FBAR) -Form 8938, Statement of Specified Foreign...more

IRS Announces Changes to Its Offshore Voluntary Disclosure and Streamlined Procedures

On June 18, 2014, the IRS announced a number of significant changes to its Offshore Voluntary Disclosure Program (OVDP) and 2012 streamlined procedure for nonresidents and the addition of a streamlined procedure for U.S....more

After All the Preparation, It’s Finally Here: FATCA Becomes Effective July 1, 2014

More than four years after Congress enacted the Hiring Incentives to Restore Employment Act of 2010, Pub. L. 111-147, which added the Foreign Account Tax Compliance Act (FATCA) provisions to the Internal Revenue Code, FATCA...more

FATCA Update: Treasury and IRS Release Wave of Guidance as July 1 Approaches

With the July 1, 2014, implementation date of the Foreign Act Tax Compliance Act (FATCA) just two days away, the Treasury Department and the Internal Revenue Service have published long-awaited, and much anticipated, guidance...more

Traps Within the new Streamline Offshore Account Disclosure Program

The new Streamlined Filing Compliance Procedures (the Streamline Procedures) go into effect July 1, 2014. Under the terms of the procedures some taxpayers will suffer no penalty for failure to timely file FBARs, (in the case...more

IRS Broadens Offshore Amnesty Program

Over the last several years, the Internal Revenue Service (IRS) has focused its efforts on enforcement of U.S. laws with respect to offshore assets held by U.S. citizens and residents, including their tax payment and...more

IRS Changes the Streamlined Filing Compliance Procedures and Offshore Voluntary Disclosure Program (OVDP) - Determining Your Most...

The IRS announced substantial changes to both the Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer Taxpayers and the Offshore Voluntary Disclosure Program (OVDP) on June 18, 2014....more

Former Head of DOJ Tax Division Warns Taxpayers to Think Twice Before Choosing New Streamlined Procedures

Former DOJ Tax Division AAG Kathy Keneally warned on June 24, 2014, that taxpayers should think carefully before signing a certification of non-willfulness and entering the IRS’s new Streamlined Filing Compliance Procedures....more

Offshore Tax Enforcement Update: Foreign Bank Account Disclosure Deadline Is June 2014

The annual deadline for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (commonly known as the “FBAR” form), is fast-approaching. Any U.S. taxpayer with a financial interest in, or signature or other...more

Hong Kong’s Long-Awaited FATCA Announcement

With deadlines looming, Hong Kong’s government announced on May 9th a much-anticipated agreement with the United States regarding the U.S. Foreign Account Tax Compliance Act (FATCA). Without this intergovernmental agreement...more

IRS Announces Sweeping Changes To Its Offshore Voluntary Disclosure Programs: New Rules Effective July 1, 2014

On Wednesday, June 18, 2014 the Internal Revenue Service announced sweeping changes to its Offshore Voluntary Disclosure Programs, effective Tuesday, July 1, 2014. Some taxpayers are treated much more leniently under expanded...more

FATCA is Coming

At the end of May 2014, a bill was introduced to the Australian Federal Parliament to give effect to the United States' Foreign Account Tax Compliance Act (FATCA) and the intergovernmental agreement which was executed by...more

Updated Roadmap To IRS’ 2014 Offshore Voluntary Disclosure Program For Taxpayers With Undisclosed Offshore Accounts

On June 18, 2014 the Internal Revenue Service (“IRS”) announced a modification to the 2012 Offshore Voluntary Disclosure Program (“OVDP”). The 2014 OVDP is a continuation of the 2012 program with modified terms. The voluntary...more

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