The Presumption of Innocence Podcast: Episode 44 - A Recipe for Litigation: The Simmering Conflict Surrounding ERC Claims
REFRESH Nonprofit Basics: Navigating the Complex Rules That Describe a Public Charity
Expedited Review of IRS Applications for Recognition of Exempt Status
Nonprofit Quick Tip: State Filings in New Mexico and Utah
Back to Compliance: Reinstating Tax-Exempt Status for a Charity
PODCAST: Williams Mullen's Benefits Companion - IRS Clarifies Emergency Distributions Tax Exceptions
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
Nonprofit Quick Tip: State Filings in Oklahoma and Texas
Inflation Reduction Act Tax Trends Begin to Take Shape
Advice for Nonprofit Investment Committees From an Investment Advisor June 3, 2024 Podcast
REFRESH: Loot and Private Foundation Rules – Part 2
IRS Dirty Dozen Warnings on Charitable Scams
US Expatriate Tax Planning - Part 1 - A Podcast with Janathan Allen
Nonprofit Quick Tip: State Filings in North Carolina and South Carolina
Nonprofit Quick Tip: State Filings in Florida and Louisiana
Business Better Podcast Episode: Tax Audits, Investigations, and Global Enforcement - A Conversation with IRS Special Agent Jonathan Schnatz
4 Key Takeaways | Harnessing the Inflation Reduction Act: Driving Investments in Renewable Energy and Carbon Reduction
Nonprofit Basics: Scholarship Grant Program IRS Approval Requirements
Nonprofit Quick Tip: State Filings in Rhode Island and New Hampshire
REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Private Foundation Advocacy
The National Taxpayer Advocate 2023 Annual Report to Congress highlights how Taxpayers abroad are underserved and continue to face challenges in meeting their U.S. tax obligations. As a result, the National Taxpayer Advocate...more
There has been a legal shakeup this summer in the world of “FBARs”—Reports of Foreign Bank and Financial Accounts. New developments have been popping up nearly every week, whether from a court decision, as a result of a...more
Después de una investigación de un año, el Comité de Finanzas del Senado de los EE. UU. investigó una escapatoria (FATCA Loophole) y entregó un Reporte de investigación titulado “The Shell Bank Loophole” que expone un esquema...more
The answer to the question “Can the IRS Collect Assets Abroad”” is yes, based on the Office of Chief Counsel Internal Revenue Service memorandum dated February 24, 2022. The memorandum discusses the IRS Collection Procedures...more
In a report to the President recommending actions to eliminate or mitigate burdens imposed on taxpayers by eight specific tax regulations, the Treasury Department indicated that it is considering possible reforms of...more
The Internal Revenue Service announced today that its FATCA FFI Registration system has been updated to allow foreign financial institutions to renew their FFI agreement with the IRS. Those financial institutions that are...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
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
Sponsoring entities should evaluate which of their sponsored entities should be registered via the IRS registration portal....more
The investigation and prosecution of tax evasion has, in the past decade, grown from a specialized subcategory of law enforcement into a first-tier policy concern for the international community. Financial institutions,...more
With less than two weeks remaining until many countries are required to exchange tax information with the U.S. pursuant to the Foreign Account Tax Compliance Act (FATCA), the U.S. has agreed to provide partner jurisdictions...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
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 IRS notice further eases, but does not delay, FATCA implementation. On May 2, the Internal Revenue Service (IRS) published Notice 2014-33 (the Notice), which announced that calendar years 2014 and 2015 will be...more
A global push for enhanced financial transparency means that United States owners of foreign accounts and assets will not be able to remain invisible forever. New rules and enhanced enforcement of existing rules will soon...more
Bloomberg BNA reports that Switzerland's parliament approved a six-month delay to enforce a bilateral Swiss-U.S. agreement on implementation of the U.S. Foreign Account Tax Compliance Act. The two chambers of the Swiss...more
On July 12, 2013, the Internal Revenue Service (IRS) issued Notice 2013-43, which extended the implementation of certain provisions of the Foreign Account Tax Compliance Act (FATCA) by six months and eliminated reporting on...more
The Internal Revenue Service (IRS) issued Notice 2013-43 (available here), which delays by six months certain of the timelines during which withholding agents and foreign financial institutions (FFIs) will be required to...more
In This Issue: Financial Industry Developments; Rating Agency Developments; RMBS and Other Securities Litigation; and, European Financial Industry Developments. ...more
IRS notice postpones FATCA withholding by six months and revises other key deadlines. ...more
On July 12, 2013, the U.S. Internal Revenue Service (IRS) issued Notice 2013-43 (Notice) which extends certain key deadlines for implementing FATCA, and provides guidance regarding the effect of these deadlines on FATCA...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 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
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
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