News & Analysis as of

Foreign Account Tax Compliance Act

The Foreign Account Tax Compliance Act is a United States federal statute enacted in 2010 as part of the Hiring Incentives to Restore Employment Act (HIRE Act). FATCA aims to improve compliance of U.S. taxpayers... more +
The Foreign Account Tax Compliance Act is a United States federal statute enacted in 2010 as part of the Hiring Incentives to Restore Employment Act (HIRE Act). FATCA aims to improve compliance of U.S. taxpayers by capturing tax revenue related to foreign assets and off-shore accounts.  less -
Eversheds Sutherland (US) LLP

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

Eversheds Sutherland (US) LLP on

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

Foodman CPAs & Advisors

Taxpayers Abroad are Underserved and Challenged

Foodman CPAs & Advisors on

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

McDermott Will & Emery

Weekly IRS Roundup July 15 – July 19, 2024

McDermott Will & Emery on

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

Conyers

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

Conyers on

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

Eversheds Sutherland (US) LLP

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

Eversheds Sutherland (US) LLP on

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

Seward & Kissel LLP

New FATCA Agreement with Switzerland

Seward & Kissel LLP on

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

Foodman CPAs & Advisors

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

Foodman CPAs & Advisors on

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

Foodman CPAs & Advisors

Tax Strategies And Schemes To Avoid Taxes At IRS Forefront

Foodman CPAs & Advisors on

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

Walkers

FATCA / CRS update: Jersey consultation announced

Walkers on

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

Conyers

Guiding Captives Through Global Developments

Conyers on

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

Conyers

Unveiling Tax Realities: Debunking Myths about the British Virgin Islands

Conyers on

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

Allen Barron, Inc.

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

Allen Barron, Inc. on

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

Allen Barron, Inc.

How Does the IRS Use AI to Identify Tax Cheats?

Allen Barron, Inc. on

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

Allen Barron, Inc.

Are There Strategies to Avoid an IRS Audit?

Allen Barron, Inc. on

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

Buchalter

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

Buchalter on

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

Proskauer - Tax Talks

Senate Finance Committee Requests Public Comments on Digital Asset Taxation

Proskauer - Tax Talks on

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

Allen Barron, Inc.

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

Allen Barron, Inc. on

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

Walkers

Guernsey Guide: legal, regulatory, transparency and supervisory framework

Walkers on

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

Walkers

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

Walkers on

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

Proskauer - Tax Talks

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

Proskauer - Tax Talks on

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

Foodman CPAs & Advisors

Las FFI Modelo 1 Obtienen Alivio Temporario De Informes FATCA

Foodman CPAs & Advisors on

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

Foodman CPAs & Advisors

¿Cuándo Son Los Casinos Instituciones Financieras?

Foodman CPAs & Advisors on

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

Foodman CPAs & Advisors

Model 1 FFIs Get FATCA Temporary Reporting Relief

Foodman CPAs & Advisors on

On 12/30/22, the IRS issued Notice 2023-11 with the purpose of providing FATCA reporting relief to Model 1 FFIs who have been unable to obtain US TINs for their pre-existing accounts that are US reportable accounts. In turn,...more

Conyers

Recent Regulatory Developments Affecting BVI Mutual Funds and Private Investment Funds

Conyers on

Requirement to appoint a Money Laundering Reporting Officer (“MLRO”) - Under the Anti-Money Laundering Regulations (Revised Edition 2020), as amended by the Anti-Money Laundering (Amendment) Regulations, 2022, and the...more

Holland & Knight LLP

¿Cuáles fiscos de América Latina reciben automáticamente información de USA y cómo funciona?

Holland & Knight LLP on

El intercambio automático y masivo entre el fisco de Estados Unidos y otros países empezó con la ley de cumplimiento fiscal de cuentas extranjeras (Foreign Account Tax Compliance Act o FATCA). FATCA es parte de una larga...more

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