News & Analysis as of

Financial Institutions Offshore Funds Internal Revenue Service

Allen Barron, Inc.

The Risks of an IRS Quiet Disclosure

Allen Barron, Inc. on

What are the risks of an IRS quiet disclosure? Is there a formal IRS process known as a "quiet disclosure," and does the IRS honor this strategy for amended tax returns?...more

Allen Barron, Inc.

What is the IRS Offshore Voluntary Disclosure Program?

Allen Barron, Inc. on

What is the IRS Offshore Voluntary Disclosure Program and who is it designed to help? What are the guidelines for voluntary disclosure to the IRS and who is eligible to apply? The IRS Offshore Voluntary Disclosure...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

Foodman CPAs & Advisors

How to Ensure FATCA and CRS Stakeholder Collaboration

OECD Report suggests compliance regime elements for FIs and Stakeholders - Foreign Account Tax Compliance Act (FATCA) and Common Reporting Standards (CRS) stakeholders are key to financial institutions’ (FIs) successful...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

Freeman Law

IRS Gets Green Light to Seek Information from Third Parties Regarding Panama Offshore Legal Services

Freeman Law on

On July 29, 2021, the United States Attorney for the Southern District of New York, the Assistant Attorney General for the Department of Justice Tax Division, and the IRS Commissioner all announced that a federal court in New...more

Dorsey & Whitney LLP

Often Overlooked Exception to Withholding and Reporting Requirements under FATCA

Dorsey & Whitney LLP on

An often overlooked exception to U.S. withholding taxes may result in a lower overall U.S. tax burden. The Foreign Account Tax Compliance Act (“FATCA”) was enacted in an effort to ensure that U.S. taxpayers could not...more

Snell & Wilmer

IRS Amends Program for Offshore Voluntary Disclosures

Snell & Wilmer on

On September 28, 2018, the Internal Revenue Service (IRS) ended its 2014 Offshore Voluntary Disclosure Program (OVDP). The 2014 OVDP (which was an extension of the 2009 and 2011 OVDPs) was meant to allow taxpayers who...more

Burr & Forman

IRS Announces End to Foreign Bank Account Disclosure Program: What Can You Do Now If You Still Have Unreported Foreign Bank...

Burr & Forman on

The IRS recently announced it will be shutting down its successful Offshore Voluntary Disclosure Program (OVDP) for unreported foreign bank accounts and income. The program will end September 28, 2018. Under the OVDP, first...more

Jones Day

Paradise Papers: The Latest Offshore Leak

Jones Day on

Hackers leaked approximately 13.4 million confidential client documents from Appleby, Estera, and Asiaciti Trust to the International Consortium of Investigative Journalists....more

Fox Rothschild LLP

Senator Rand Paul Once Again Takes Aim At FATCA

Fox Rothschild LLP on

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

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

¡Primera Convicción de FATCA!

El 9 de Mayo del 2016, el Departamento de Justicia (DOJ) anunció su primera convicción usando FATCA. Parece ser el principio de procesos penales por el DOJ contra violaciones aparentes o presuntas de los requisitos de...more

Holland & Knight LLP

Panama Papers Fallout: A Push for Transparency and Regulatory Reform - Sanctions Also Levied Against Several Panama-Based...

Holland & Knight LLP on

In the wake of the "Panama Papers" – the unprecedented leak of 11.5 million files from a Panamanian law firm that revealed thousands of names and addresses linked to offshore companies – the White House has announced several...more

Sheppard Mullin Richter & Hampton LLP

In Wake of Panama Papers Scandal Obama Calls for Stricter Bank Regulations, Tax Rules

In a news conference May 6, President Obama addressed recently announced rules and proposed regulations intended to help the U.S. fight tax evasion and other crimes connected to anonymous offshore companies and accounts. The...more

Sheppard Mullin Richter & Hampton LLP

In Wake of Panama Papers Scandal Obama Calls for Stricter Bank Regulations, Tax Rules

In a recent news conference President Obama addressed rules and proposed regulations announced Thursday intended to help the U.S. fight tax evasion and other crimes connected to anonymous offshore companies and accounts. The...more

BakerHostetler

BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement

BakerHostetler on

Global tax enforcement is the number one priority of the U.S. authorities, and they are using their resources and tools in unprecedented ways to ensure that those who intentionally evade taxes are identified and brought to...more

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