Tax Law

Recent Posts

Strengthening Procedures Against Tax Evasion
Posted on 20 Nov 2013 by Henry (Terry) Christensen III, Esq.

by Henry Christensen III * The events involving Union Bank of Switzerland ("UBS") have resulted in federal criminal prosecutions, a deferred prosecution agreement between the U.S. Department of Justice and UBS and a separate global settlement... Read More

FATCA Imposes Burdens on NFFEs
Posted on 22 Jan 2013 by LexisNexis Tax Law Community Staff

by Lawrence A. Kogan* The Foreign Account Tax Compliance Act of 2010 (FATCA) and its regs impose certain information gathering, reporting and withholding requirements on nonfinancial foreign entities (NFEEs) operated by U.S. taxpayers overseas. In part... Read More

IGA Flurry Shows U.S. Is Locking Down on FATCA
Posted on 12 Dec 2012 by Allison Christians

A recent flurry of signed IGAs and press releases on ongoing negotiations suggests the US is acting tremendously quickly and even brazenly on FATCA. Almost as if they are trying to get this all nailed down before anyone outside the US government has time... Read More

Reporting Obligations of U.S. Beneficiaries of Foreign Trusts and New Form 8938
Posted on 18 Dec 2012 by Diane L. Mutolo

In 2010, Congress enacted the Foreign Account Tax Compliance Act (FATCA) as part of the Hiring Incentives to Restore Employment Act ("the HIRE Act"), and the legislation amended the Internal Revenue Code with the goal of increasing foreign account... Read More

Reporting Specified Financial Assets and Form 8938
Posted on 18 Dec 2012 by Neil Aragones

U.S. taxpayers with assets overseas and their advisers should be mindful of new Form 8938, Statement of Specified Foreign Financial Assets , as they prepare the taxpayers' federal income tax returns for 2011. Temporary Regulations issued in December... Read More

U.K., U.S. Agree on Compliance, Information Reporting, Withholding Provisions (FATCA)
Posted on 18 Dec 2012 by Karen Yip

According to Treasury Department News Release TDNR TG-1711 (September 14, 2012), the United Kingdom and the United States have entered into an agreement to implement the information reporting and withholding tax provisions known as the Foreign Account... Read More

Definition Added to FATCA Requirements Landscape
Posted on 27 Feb 2012 by Neil Aragones

Proposed Regs Revise FATCA's Due Diligence Procedures: Pre-existing Individual Accounts and Electronic Searches The much-anticipated proposed regulations under the Foreign Account Tax Compliance Act (FATCA) have been issued by the Treasury, and... Read More

FATCA Compliance Programs
Posted on 24 Mar 2014 by William H. Byrnes IV

By Prof. William H. Byrnes and Dr. Robert J. Munro * Editor's Note: The following is an excerpt from Chapter 2 of the 2014 edition of LexisNexis Guide to LexisNexis® Guide to FATCA Compliance by William Byrnes and Robert Munro, published February... Read More

Reporting and Withholding Guidance: Payments to FFIs Under FATCA
Posted on 2 Apr 2012 by LexisNexis Tax Law Community Staff

Editor's Note : This narrative is derived from Tax Controversies: Audits, Investigations, Trials § 17.04 (Matthew Bender) by Robert S. Fink, J.D., LL.M., Kostelanetz & Fink, LLP, New York, N.Y. ... The Foreign Account Tax Compliance Act... Read More

  • Blog Post: Definition Added to FATCA Requirements Landscape

    Proposed Regs Revise FATCA's Due Diligence Procedures: Pre-existing Individual Accounts and Electronic Searches The much-anticipated proposed regulations under the Foreign Account Tax Compliance Act (FATCA) have been issued by the Treasury, and among the lengthy provisions is significant guidance...
  • Blog Post: Reporting and Withholding Guidance: Payments to FFIs Under FATCA

    Editor's Note : This narrative is derived from Tax Controversies: Audits, Investigations, Trials § 17.04 (Matthew Bender) by Robert S. Fink, J.D., LL.M., Kostelanetz & Fink, LLP, New York, N.Y. ... The Foreign Account Tax Compliance Act, or FATCA, enacted in March 2010 and codified at...
  • Blog Post: IGA Flurry Shows U.S. Is Locking Down on FATCA

    A recent flurry of signed IGAs and press releases on ongoing negotiations suggests the US is acting tremendously quickly and even brazenly on FATCA. Almost as if they are trying to get this all nailed down before anyone outside the US government has time to study it and think it through. This is absurd...
  • Blog Post: Reporting Specified Financial Assets and Form 8938

    U.S. taxpayers with assets overseas and their advisers should be mindful of new Form 8938, Statement of Specified Foreign Financial Assets , as they prepare the taxpayers' federal income tax returns for 2011. Temporary Regulations issued in December 2011 state that, with certain exceptions, Form...
  • Blog Post: U.K., U.S. Agree on Compliance, Information Reporting, Withholding Provisions (FATCA)

    According to Treasury Department News Release TDNR TG-1711 (September 14, 2012), the United Kingdom and the United States have entered into an agreement to implement the information reporting and withholding tax provisions known as the Foreign Account Tax Compliance Act (FATCA) (enacted as part of the...
  • Blog Post: Reporting Obligations of U.S. Beneficiaries of Foreign Trusts and New Form 8938

    In 2010, Congress enacted the Foreign Account Tax Compliance Act (FATCA) as part of the Hiring Incentives to Restore Employment Act ("the HIRE Act"), and the legislation amended the Internal Revenue Code with the goal of increasing foreign account tax reporting and compliance. [The Hiring Incentives...
  • Blog Post: FATCA Imposes Burdens on NFFEs

    by Lawrence A. Kogan* The Foreign Account Tax Compliance Act of 2010 (FATCA) and its regs impose certain information gathering, reporting and withholding requirements on nonfinancial foreign entities (NFEEs) operated by U.S. taxpayers overseas. In part, FATCA is intended to address difficulties that...
  • Blog Post: Strengthening Procedures Against Tax Evasion

    by Henry Christensen III * The events involving Union Bank of Switzerland ("UBS") have resulted in federal criminal prosecutions, a deferred prosecution agreement between the U.S. Department of Justice and UBS and a separate global settlement between the U.S. Department of Justice, the Swiss...
  • Blog Post: FATCA Compliance Programs

    By Prof. William H. Byrnes and Dr. Robert J. Munro * Editor's Note: The following is an excerpt from Chapter 2 of the 2014 edition of LexisNexis Guide to LexisNexis® Guide to FATCA Compliance by William Byrnes and Robert Munro, published February 2014. Chapter 2 contributors: Jeffrey Locke...