Tax Law

Recent Posts

FATCA: Identifying US-related Swiss Bank Accounts
Posted on 18 Dec 2015 by LexisNexis Tax Law Community Staff

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... Read More

Why FATCA Is A Tax Treaty Override
Posted on 21 Jan 2013 by Allison Christians

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... Read More

IRS' FATCA Registration System
Posted on 21 Aug 2013 by William H. Byrnes IV

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.... Read More

Why FATCA Is A Tax Treaty Override
Posted on 21 Jan 2013 by Allison Christians

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... Read More