BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement
Correcting Problems With Your Retirement Plan
FCPA Compliance and Ethics Report-Episode 63-Managing the Third Party Relationship Under the FCPA, Part I
Thomson Reuters Session 2: Investment Management, Hedge Funds and Registered Mutual Funds: What's Happening Now?
Did the IRS Just Help or Hurt the Bitcoin Economy?
Tax Traps of Employment Documents
BB&K's Isabel Safie Discusses the Implications of IRS’ Definition of Governmental Plan Status
Fantasy Football: The Legal Reality
Hot Topics for Waste-to-Energy Investors and Developers
The month of July has seen several significant developments regarding implementation of the Foreign Account Tax Compliance Act (FATCA), which has been fully effective since July 1, 2014. First, the IRS Office of Chief...more
A recent decision of the Third Circuit Court of Appeals illustrates the futility of expecting that the Fifth Amendment Privilege Against Self-incrimination will shield taxpayers from production of offshore financial records. ...more
Senator Rand Paul, R-Ky., along with six current and former U.S. citizens living abroad, filed a lawsuit, July 14, in the U.S. District Court for the Southern District of Ohio challenging the constitutionality of the Foreign...more
While the Foreign Account Tax Compliance Act (FATCA) became law in 2010, it has been slowly transitioning to implementation, with 2015 being the first year of required reportings. For anyone not familiar with the Act, FATCA...more
Today the Internal Revenue Service issued two public notices reminding taxpayers of their obligations to report foreign assets as the June 30 FBAR deadline fast approaches. Each notice referred to the extensive guidance...more
More and more, U.S. taxpayers are becoming aware of their federal tax reporting obligation for foreign financial accounts, interests and assets. With increased IRS enforcement, broader media coverage of international tax...more
While FBAR reporting rules are frequently misunderstood, US persons have several options to correct mistakes, before the government learns of the non-compliance.
June 30th is the annual deadline for filing a Foreign...more
Tax fraud occurs on a considerable scale that can exceed law enforcement’s ability to detect and punish the conduct. This is true at both the federal and state levels. As of 2015, the Internal Revenue Service (“IRS”) and the...more
Chapter 3 of the Internal Revenue Code requires payors (and recipients) of certain types of U.S. source income to withhold tax if the beneficial owner or recipient is a non-U.S. person for income tax purposes. Chapter 4 also...more
The first non-prosecution agreement signals expanded US tax enforcement opportunities at home and abroad.
The US Department of Justice (DOJ) has announced the first non-prosecution agreement (NPA) with BSI, SA, (BSI)...more
Virtual currency is a new, untested, and unregulated asset. The Internal Revenue Service (IRS) defines “virtual currency” as a digital representation of value that functions as a medium of exchange, a unit of account, and/or...more
NUMBER OF THE WEEK: $23 Billion. The total revenue generated by the additional Medicare tax and the net investment income tax used to pay for the Affordable Care Act. The total exceeds the Joint Committee on Taxation’s 2010...more
As part of the Foreign Account Tax Compliance Act (FATCA) passed by Congress in 2010, individual taxpayers are now required to report “specified foreign financial assets” on an information reporting form entitled Form 8938,...more
Are you an American abroad living in perpetual fear of the IRS? Do you wake up every morning wondering if today you’ll receive a formidable notice that the taxman cometh? You are not alone. ...more
A foreign bank asks our client to provide information that the bank is not required to provide IRS under FATCA. There are two possibilities. Our client can provide the information or our client can choose not to provide the...more
NUMBER OF THE WEEK: 3,415. The number of people who renounced their citizenship in 2014 according to IRS data. This is one of the five highest totals on record since the U.S. Congress passed the Foreign Account Tax Compliance...more
After several years of delays, the Foreign Account Tax Compliance Act (FATCA) finally took effect on July 1, 2014. Congress enacted FATCA as part of the Hiring Incentives to Restore Employment Act in 2010 to stop U.S....more
The IRS has unveiled a secure web application, the International Data Exchange Service (IDES), for cross-border data sharing. IDES will allow Foreign Financial Institutions (FFIs) and tax authorities from other countries to...more
In a series of Frequently Asked Questions releases December 31, 2014, The Congressional Research Service provides some guidance on when non-U.S. citizens may be subject to U.S. income taxes....more
1. The United States announced the signing of two more Intergovernmental Agreements (IGAs) to implement FATCA. The latest IGAs were signed by the Netherlands and Curacao, and are dated December 18 and 16, respectively. Both...more
The future for offshore tax planning, also known as “aggressive tax planning” is likely to be limited to if not curtailed by the global exchange of information agreement signed in October, 2014 by 51 countries and growing....more
On December 1, 2014, Treasury and the IRS issued Announcement 2014-38 which provides relief to those countries which have reached FATCA Intergovernmental Agreements (IGAs) in substance, but have not signed such agreements....more
On 2 December 2014, the US and Cyprus governments signed an intergovernmental agreement (IGA) to implement the Foreign Account Tax Compliance Act (FATCA). There are two types of IGAs known as "Model 1" and "Model 2". The...more
The deadline for compliance with both US FATCA and UK FATCA fast approaches.
Cayman entities which are classified as Financial Institutions are within the scope of FATCA. A typical Cayman fund will fall within the...more
Under transitional relief, certain non-U.S. investment funds, including Cayman Islands funds, that qualify as foreign financial institutions (FFIs), have been permitted to certify their status under the U.S. Foreign Account...more
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