Best Practices under the FCPA updated Resource Guide

July 2020

On July 3, 2020, the US Department of Justice (DOJ) released “A Resource Guide to the U.S. Foreign Corrupt Practices Act, Second Edition”.  This updated edition is a concerted effort of the DOJ, Securities Exchange Commission (SEC), the US Department

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Audit Time for High Income Individuals and their Companies has arrived

July 2020

On a webinar hosted by the New York University Tax Controversy Forum on June 18, 2020, Douglas O’Donnell (head of the IRS Large Business and International Division/IRS-LBI) stated that the IRS will  begin a new campaign to audit hundreds of

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Willfulness and IRS Foreign Account Reporting Requirements

July 2020

The IRS Mission Statement states that: “the taxpayer’s role is to understand and meet his or her tax obligations”.   Taxpayers fill out their own returns under a “self-assessment voluntary reporting system” because the Taxpayer is the one that possess all

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Are you Managing your Fraud Risk Proactively?

July 2020

Managing fraud risk proactively is imperative. It is not only about protecting against financial losses commonly associated with fraud.  It is also about surviving reputational risk.  There is a need for Organizations to create an environment and implement appropriate controls

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Did you know that IRS reinstated the “ASFR” program in 2019?

July 2020

Under Internal Revenue Code, Section 6620, if a Taxpayer does not timely file a U.S. tax return, the IRS is authorized to prepare and file a U.S. tax return for that Taxpayer based on the knowledge that it has on

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Does your Third-Party FATCA Consultant have the experience to interpret the complex US Tax Code?

July 2020

Foreign Financial Institutions (FFIs) have multiple FATCA reporting compliance responsibilities and face the possibility of penalties for not complying.  Understanding and interpreting more than 1,000 pages of FATCA regulations requires an underlying comprehension of their words (a new vocabulary) and

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FCInet is Connecting Data with different Worldwide Tax Organizations

July 2020

In 2018, the Organization for Economic Co-operation and Development (OECD) issued a “call to action” for countries to do more to tackle enablers of tax crimes. The result of this “call to action” was the establishment of an operational alliance

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How does the “Accounting” for a Forgivable Loan received under the PPP work?

June 2020

The PPP (Paycheck Protection Program) was established by Congress to assist small businesses during the Covid-19 pandemic as part of the $2 trillion CARES Act.  Via the PPP, the U.S. Treasury requires the U.S. Small Business Administration (SBA) to fund

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The FATF identifies Money Laundering Threats arising from the Covid-19 Crisis

June 2020

On May, 2020, the FATF published new money laundering and terrorist financing threats and vulnerabilities arising from the COVID-19 crisis.  The document highlights how fraud, cybercrime, misdirection of government funding and international financial assistance are opening the way for illicit

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FCPA Compliance Report-Episode 482 – Stanley Foodman on the Travel Act and FCPA

June 2020

Thomas Fox has practiced law in Houston for 30 years. He is an Independent Consultant, assisting companies with anti-corruption and anti-bribery compliance and international transaction issues. He specializes in bring business solutions to compliance problems. In the Episode, I am

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The “Affidavit” in the IRS Streamlined Filing Compliance Procedures is a Key Component

June 2020

Streamlined Filing Compliance Procedures (Streamlined) is one of the options available for US Taxpayers with unreported foreign financial assets and income.  The intention of the program is to provide non-willful uncompliant Taxpayers with a less stressful path toward recovering compliant

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The OVDP is now the VDP

June 2020

There was and IRS termination of the Offshore Voluntary Disclosure Program (OVDP) on September 28, 2018. On November 20, 2018, following the OVDP notice of termination, there was a release of a Memorandum announcing the Voluntary Disclosure Practice. On May

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