By William H. Byrnes and Robert J. Munro *
Swiss banks that elected to participate in the Department of Justice Program for Non-Prosecution Agreements or Non-Target Letters for Swiss banks (the "Program") are required to identify "U...
I've been asked to explain comments I made in a recent talk about FATCA, when I said that this regime constitutes a tax treaty override, and that I don't think that IGAs are a valid fix as a matter of law. Here is my reasoning. I will use the...
By Professor William Byrnes , - co-author of LexisNexis® Guide to FATCA Compliance ; co-author of Foreign Tax & Trade Briefs
FATCA Registration Portal Open for Business
F ATCA requires that FFIs, through a responsible officer (a.k.a....