In response to the COVID-19 pandemic, the IRS has granted foreign financial institutions a number of extensions on Foreign Account Tax Compliance Act reporting obligations due in 2020...more
In response to the COVID-19 pandemic, the Internal Revenue Service has agreed to extend many deadlines. One such extension affords foreign financial institutions more time to file Form 8966. Form 8966 is the annual...more
In response to Executive Orders requiring a broad federal review of existing regulations, Treasury and IRS issued this morning proposed regulations easing certain compliance burdens imposed on foreign financial institutions...more
Today the IRS published a reminder to foreign financial institutions and their compliance officers that certifications required by the Foreign Account Tax Compliance Act (FATCA) are due no later than December 15, 2018. This...more
On September 29, 2018, the Internal Revenue Service closed for good the long-running Offshore Voluntary Disclosure Program (OVDP), its hugely successful tax amnesty program for undisclosed offshore financial assets. Since...more
The Internal Revenue Service’s Large Business and International division (LB&I) announced the approval of five additional compliance campaigns. LB&I announced on January 31, 2017, the rollout of its first 13 campaigns,...more
In a move sure to send shock waves through the offshore banking community, the Justice Department yesterday announced its first criminal conviction for violating the Foreign Account Tax Compliance Act (FATCA). Adrian Baron,...more
The Internal Revenue Service has issued a warning to taxpayers about avoiding taxes by hiding money or assets in unreported offshore accounts, a tax scam that remains on the annual “Dirty Dozen” for 2018. Offshore tax...more
The Foreign Account Tax Compliance Act (FATCA) requires a foreign financial institution to appoint a “Responsible Officer” who is obligated to submit periodic compliance certifications to the Internal Revenue Service...more
Yesterday the International Consortium of Investigative Journalists released information from the corporate registries of four more tax havens that were included in the Paradise Papers investigation: Barbados, the Bahamas,...more
In the midst of the tax reform debate currently embroiling Congress, Senator Rand Paul (R-Kentucky) has introduced an amendment seeking to repeal the Foreign Account Tax Compliance Act (FATCA), an anti-tax evasion law enacted...more
Tomorrow morning (November 17) the International Consortium of Investigative Journalists (ICIJ) is set to release publicly the first set of comprehensive data from the recent “Paradise Papers” leak. The initial data will...more
With tax reform a hot topic in Washington, key Republican lawmakers in Congress are considering a major change to the U.S. tax system: eliminating citizenship-based taxation and moving to a residence-based system, according...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 has issued a reminder to foreign financial institutions to renew their Foreign Financial Institution (FFI) agreement if required. These FFIs have until October 24, 2017 to complete their renewal....more
The Internal Revenue Service has extended the deadline for foreign financial institutions (FFIs) to renew their FFI Agreements to October 24, 2017. We previously wrote about the IRS’ publication in late 2016 of an updated...more
We have previously written about the Internal Revenue Service’s publication in late 2016 of an updated “FFI Agreement” to be entered into by foreign financial institutions that wish to remain compliant with the Foreign...more
The Internal Revenue Service has released an updated version of its “FATCA Online Registration User Guide.” The updates primarily address the newly-released FFI agreement renewal function, which is now available on the IRS...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
The U.S. Attorney’s Office for the Eastern District of New York has charged four individuals with securities fraud conspiracy for their involvement in fraudulently manipulating the stock of a U.S. company using a traditional...more
Following its publication on December 30, 2016, of an updated FFI agreement, the Internal Revenue Service has published a reminder to financial institutions about renewing their FFI agreement. All financial institutions that...more