Editor's Note: The following was derived from the U.S. Senate web site page of Carl Levin (D - MI) ... On July 12th, Sen. Carl Levin, D-Mich., together with cosponsors Senators Conrad, Bill Nelson, Sanders, Shaheen, and Whitehouse, introduced... Read More
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
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
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
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
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
The proposed regulations were released as a 388-page document, now available on the IRS website: http://www.irs.gov/pub/newsroom/reg-121647-10.pdf . From IRS.gov : The regulations lay out a step-by-step process for U.S. account identification, information... Read More
Sudden changes are seldom witnessed in the tax world. History teaches that for every brilliant tax reform proposal, there is a well-organized lobby seeking to preserve the status quo. Consider offshore tax evasion. For decades policymakers have decried... Read More
By Steven D. Bortnick and Timothy J. Leska , Attorneys, Pepper Hamilton LLP In March 2009, Sen. Carl Levin (D-Mich.) introduced the Stop Tax Haven Abuse Act (S. 506) (the 2009 Act) to "stop tax cheats" and target "off-shore tax abuses... Read More
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
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
The Foreign Account Tax Compliance Act of 2009 (FATCA), introduced on October 27, 2009 and supported by many, including President Obama and Treasury Secretary Timothy Geithner, seeks to combat tax evasion through the use of offshore intermediaries by... Read More
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
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