FATCA | JD Supra

Breaking Up: Why U.S. Citizens Living Abroad Renounce Citizenship

Jackson Lewis P.C. on 12/4/2024

Approximately nine million U.S. citizens live or work abroad, and some want to renounce their U.S. citizenship. Many do so with regret but renounce to avoid various financial issues. Others consider themselves “accidental...more

Model 1 FFI’s Obtain Extension of Relief

Foodman CPAs & Advisors on 11/21/2024

IRS issued Notice 2024-78 on 10/28/24 providing the extension of temporary relief for FATCA Model 1 Financial Institutions (FFI’s) regarding the reporting of U.S. Taxpayer Identification Numbers. This means that the temporary...more

British Virgin Islands comparison of open-ended funds

Carey Olsen on 11/6/2024

In this guide we compare the five types of open-ended funds in the British Virgin Islands (the “BVI”), being private funds, professional funds, public funds, incubator funds and approved funds (this guide does not cover...more

Relief arrives for certain Model 1 FFIs that do not transmit US TINs to IRS

Eversheds Sutherland (US) LLP on 10/30/2024

Notice 2023-11, issued in December 2023, provided limited relief to certain foreign financial institutions (FFIs) that were not fully in compliance with the terms of their Model 1 FATCA Intergovernmental Agreement (IGA)....more

Taxpayers Abroad are Underserved and Challenged

Foodman CPAs & Advisors on 9/6/2024

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

Weekly IRS Roundup July 15 – July 19, 2024

McDermott Will & Emery on 7/29/2024

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 15, 2024 – July 19, 2024. ...more

Regulatory & Risk Advisory Review: Cayman Islands - April to June 2024

Conyers on 7/23/2024

Welcome to the second instalment of 2024 of the Regulatory & Risk Advisory Review. In this edition we cover several Cayman Islands regulatory updates including updates to the Beneficial Ownership Transparency Act, the...more

Swiss sign Model 1 IGA with United States and resolve transition issues

Eversheds Sutherland (US) LLP on 7/19/2024

On June 27, 2024, Switzerland and the United States executed the Agreement between Switzerland and the United States of America to Improve International Tax Compliance and to Implement FATCA (New IGA), which will take effect...more

New FATCA Agreement with Switzerland

Seward & Kissel LLP on 7/19/2024

The United States and Switzerland jointly announced the conversion of the intergovernmental agreement (“IGA”) from a “Model 2” to “Model 1” agreement. The new IGA will come into effect January 1, 2027, allowing time for...more

Estrategias Y Esquemas Tributarios Para Evitar Impuestos A La Vanguardia Del IRS

Foodman CPAs & Advisors on 5/20/2024

El 11/04/24, el IRS concluyó su Lista de la Docena Sucia de 2024 con una “advertencia a los contribuyentes sobre los promotores que venden estrategias fiscales falsas y esquemas extraterritoriales fraudulentos diseñados para...more

Tax Strategies And Schemes To Avoid Taxes At IRS Forefront

Foodman CPAs & Advisors on 5/20/2024

On 4/11/24, the IRS wrapped up its 2024 Dirty Dozen List with a “warning to taxpayers regarding promoters selling bogus tax strategies and fraudulent offshore schemes designed to reduce or avoid taxes altogether”. Tax...more

FATCA / CRS update: Jersey consultation announced

Walkers on 2/26/2024

The Minister for External Relations of the Government of Jersey (GoJ) recently announced a public consultation seeking views on a number of proposed changes to the operation of the Common Reporting Standard (CRS) and the US...more

Guiding Captives Through Global Developments

Conyers on 2/21/2024

Bermuda formed the first modern captive in 1962 and remains the leading offshore captive domicile, with approximately 700 licenced captives on its register. Bermuda’s captive industry has remained resilient in the face of...more

Unveiling Tax Realities: Debunking Myths about the British Virgin Islands

Conyers on 2/5/2024

In this review of taxation and the British Virgin Islands, Conyers Corporate Counsel Nicholas Kuria discusses some of the most commonly misunderstood notions relating to the use of offshore jurisdictions, with a focus on the...more

Is it Time to Rethink Your Offshore PFIC Investment(s)?

Allen Barron, Inc. on 12/21/2023

Is it time to rethink your offshore PFIC investment(s)? What is a PFIC and why should you be concerned about the impact it will have upon taxation? Why should investment in a PFIC concern you as a US taxpayer?...more

How Does the IRS Use AI to Identify Tax Cheats?

Allen Barron, Inc. on 12/13/2023

Could Artificial Intelligence (AI) increase the likelihood of an IRS audit in your future? How does the IRS use AI to identify US taxpayers who attempt to hide assets, under-report income or otherwise cheat the IRS? In...more

Are There Strategies to Avoid an IRS Audit?

Allen Barron, Inc. on 11/28/2023

Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more

FBARs, FATCA, and Foreign Nationals: Where are We Headed?

Buchalter on 8/30/2023

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

Senate Finance Committee Requests Public Comments on Digital Asset Taxation

Proskauer - Tax Talks on 8/30/2023

On July 11, 2023, the Senate Finance Committee released an open letter to the Digital Asset Community asking a variety of questions in connection with possible future legislation. Public comments must be emailed to the Senate...more

An International Tax Primer for US Taxpayers and Expatriates – Part 1 of 2

Allen Barron, Inc. on 8/24/2023

Welcome to part 1 of our Allen Barron International Tax Primer for US Taxpayers and Expatriates. The United States is one of the few countries in the world that taxes its citizens on their worldwide income. US taxpayers are...more

Guernsey Guide: legal, regulatory, transparency and supervisory framework

Walkers on 8/9/2023

This briefing explains Guernsey’s adoption of rigorous international tax and regulatory standards, which, in conjunction with its local tax law, make it an ideal location for investment funds and other investment vehicles....more

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

Walkers on 8/7/2023

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

Recent Legislative Proposals and IRS Guidance on the Taxation of Digital Assets

Proskauer - Tax Talks on 5/2/2023

This blog post summarizes recent federal bills that have been introduced (but not yet passed), proposals by the Biden Administration, and guidance issued by the Internal Revenue Service with respect to the taxation of digital...more

Las FFI Modelo 1 Obtienen Alivio Temporario De Informes FATCA

Foodman CPAs & Advisors on 1/12/2023

El 12/30/22, el IRS emitió el Aviso 2023-11 con el propósito de proporcionar alivio de informes FATCA a las FFI Modelo 1 que no han podido obtener los TINs (“Tax ID Numbers”) de los EE. UU. para sus cuentas preexistentes que...more

¿Cuándo Son Los Casinos Instituciones Financieras?

Foodman CPAs & Advisors on 1/10/2023

De acuerdo con el IRS y FinCEN, los casinos con licencia para hacer negocios como casinos y que tienen ingresos brutos anuales de juego superiores a $1,000,000 son instituciones financieras sujetas a los requisitos de la Ley...more

Foreign Account Tax Compliance Act

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