A group of Canadians has put together a campaign to explore the constitutional violations posed by FATCA in Canada. Some of these issues were raised by pre-eminent constitutional scholar Peter Hogg, in this letter to Finance . Others arise because of... Read More
by Prof. William H. Byrnes IV and Dr. Robert J. Munro * Editor's Note: The following excerpts are from Chapter 4 of the forthcoming 2014 edition of LexisNexis® Guide to FATCA Compliance by William Byrnes and Robert Munro, scheduled for publication... 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
In a joint statement, the governments of the United States, France, Germany, Italy, Spain and Britain stated they wished to increase cooperation in fighting international tax evasion. This would work in both directions-the European nations providing information... Read More
On April 30, 2014 the IRS released the new Form W-8IMY (“ Form W-8IMY ”), formally replacing its 2006 predecessor W-8IMY. This new Form W-8IMY has 28 parts, whereas the previous August 2013 FATCA draft W-8IMY only contained 26. The new 2014... Read More
Norway signed an IGA with the US Treasury on April 15. I blacklined the Norway agreement against the Model 1 FATCA, (you can download the comparison here ) and note that some of the regular features appear, including deemed-compliance status for pension... Read More
On Saturday, March 22, 2014 the EU Council’s General Secretariat announced that it will adopt major amendments to the EU Directive on taxation of savings income at its next meeting. The amendments will address the current loopholes, such as application... Read More
By Karen Yip, LexisNexis Federal & International Tax Analyst The IRS requires the Report of Foreign Bank and Financial Accounts, TD F 90-22.1 (commonly known as the Foreign Bank Account Report, or "FBAR"), when a U.S. person has a financial... Read More
Treasury released Notice 2014-33 on May 2. Notice 2014-33 provides aspects of temporary relief for five areas of FATCA compliance: 1. 6 month extension (from July 1, 2014 until December 31, 2014) for characterizing as “pre-existing” the... 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
By Prof. William H. Byrnes IV and Dr. Robert J. Munro * ...The Joint Statement between the U.S., France, Germany, Italy, Spain and the United Kingdom regarding an intergovernmental approach to improving international tax compliance and implementing... Read More