News & Analysis as of

Banks Foreign Account Tax Compliance Act

Walkers

What can we learn from recent enforcement actions in the Cayman Islands?

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Walkers' regulatory partners Lucy Frew and Ian Mason consider the learning points for financial services providers (FSPs) from recent enforcement actions by Cayman regulatory bodies. While financial services and related...more

Foodman CPAs & Advisors

How Tax Administrations Handle FATCA, CRS Non-Compliance

Tax administrations can use a combination of detective, preventative and corrective measures to assess and treat Foreign Account Tax Compliance (FATCA) and Common Reporting Standard (CRS) non-compliance, according to the...more

Eversheds Sutherland (US) LLP

BEAT, FATCA and Insurance - proposed regulations clarify the application of the BEAT and the treatment of insurance premiums under...

On December 13, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued two sets of proposed regulations of importance to insurance companies. One set was the long-awaited regulations...more

Butler Snow LLP

Are you caught in the CRS “Triangulation Problem”?

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The Common Reporting Standard (“CRS”), following along the precedent set by the Foreign Account Tax Compliance Act (“FATCA”), creates the concept of “accountholders” in structures such as trusts, foundations, companies and...more

Foodman CPAs & Advisors

Traps for the Unwary: Are Financial Institution receiving adequate FATCA consulting and training?

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

Foodman CPAs & Advisors

Bankers, Do your US Clients tell you everything that you need to know?

Given the information publicly revealed by “Panama Papers”, and recent IRS reminders to out-of-compliance US Taxpayers to come into full compliance with their federal tax obligations, it is critical that Bankers and Financial...more

Foodman CPAs & Advisors

If you are an “Expat”, or thinking about “Expatriating”, think about this!

Thinking about giving up your US citizenship pending the results of the Presidential election in November 2016? Concerned because you have been an “Expat” for a long time and have not filed US Tax returns? Just realized that...more

Foodman CPAs & Advisors

“Spider Webs”, “Panama Papers” and IRS

IRS has asked involved U.S. taxpayers to come forward before IRS reads and dissects the “Panama Papers”. IRS will “plan how to use the huge trove of leaked documents to catch criminals — and urged Americans to come clean now...more

Blank Rome LLP

FATCA Update: Institute of International Bankers Submits Comment Letter on FATCA Regulations

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The Institute of International Bankers (IIB) has submitted a comment letter (available through Bloomberg BNA here; subscription required) to the Internal Revenue Service addressing various issues arising under the FATCA...more

BakerHostetler

AML and Investment Advisers: Understanding FinCEN's New Anti-Money Laundering Rules

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On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed rulemaking that would require registered investment advisers, including certain hedge funds and asset managers, to establish anti-money laundering...more

Latham & Watkins LLP

Foreign Banks and Bankers Face New Risks From Swiss Bank Amnesty

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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

Blake, Cassels & Graydon LLP

Year in Review: Legislation and Guidance for Financial Institutions in 2014

2014 was a year replete with new legislative and regulatory initiatives impacting federally regulated financial institutions. The key initiatives introduced or implemented in 2014 are outlined in our annual year in review....more

Blank Rome LLP

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

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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

Fenwick & West LLP

U.S. Tax Developments Affecting Financial Institutions and Products

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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

Latham & Watkins LLP

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

Latham & Watkins LLP on

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

Morrison & Foerster LLP

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

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

New York's Highest Court Will Review First Department Decision on RMBS Putback Statute of Limitations - On June 27, the Court of Appeals for the State of New York agreed to review the First Department's December 2013...more

The Volkov Law Group

On The Chopping Block: Banks And Financial Institutions

The Volkov Law Group on

The Department of Justice has had enough. Banks and other financial institutions are not just on the radar screen – they are on the chopping block. One-by-one watch out – banks and other financial institutions are coming...more

Goodwin

IRS Notice 2014-33 – IRS Grants Relief for Good-Faith Efforts Under FATCA

Goodwin on

On May 2, 2014, the Internal Revenue Service (“IRS”) issued Notice 2014-33 (the “Notice”) providing that calendar years 2014 and 2015 will be regarded as a transition period for purposes of IRS enforcement and administration...more

Morgan Lewis

IRS Announces Transitional Period for FATCA Enforcement, Other FATCA Rule Changes

Morgan Lewis on

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

Holland & Knight LLP

IRS Announces Easing Of FATCA Enforcement For 2014 And 2015

Holland & Knight LLP on

HIGHLIGHTS - - The IRS has issued a Notice detailing temporary modifications to its enforcement rules having to do with the Foreign Account Tax Compliance Act. - Under IRS Notice 2014-33, 2014 and 2015 will be...more

Holland & Knight LLP

As Swiss Banking Becomes More Transparent, Americans with Undeclared Swiss Accounts Are Warned

Holland & Knight LLP on

In a move that was likely celebrated by United States governmental officials, Swiss banking secrecy eroded even further on Thursday, March 6, 2014. This is the day that parliament voted to provide foreign tax authorities with...more

Foley Hoag LLP

FATCA: With Deadlines Looming, the Time to Act is Now

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On July 1, 2014, FATCA will go into effect. As a consequence, foreign entities that receive payments or allocations of certain U.S.-source income generally will be subject to a new 30 percent U.S. withholding tax on such...more

BakerHostetler

U.S. Signs Four More FATCA IGA’s

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On February 5, 2014, the Treasury Department announced that it had recently concluded FATCA IGA’s with Canada, Hungary, Italy, and Mauritius. All four agreements were reciprocal Model 1 agreements. In other words, FFI’s in...more

K&L Gates LLP

The Cloak of Invisibility for Foreign Accounts Is Rapidly Unraveling: IRS and Foreign Banks Are Clamping Down on U.S. Tax Evasion

K&L Gates LLP on

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

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