FATCA: “COPA” and “PERIODIC CERTIFICATIONS” due by July 1, 2018, will have, in effect, a 3 Month Extension. BUT, will you be READY?

April 2018

On March 19, 2018, IRS released “Draft FATCA Certification Questions” (https://www.irs.gov/businesses/corporations/draft-fatca-certifications)  to be completed by the Responsible Officer (RO) of a Participating Foreign Financial Institution (FFI) or Reporting Model 2 FFI.    The FATCA certifications are known as COPA (for certification of an Entity’s preexisting

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No relief in sight for US Expatriates worldwide as Duplicative Reporting Requirements Continue to Burden US Expatriate Taxpayers

March 2018

The National Taxpayer Advocate Report for 2017 (Purple Book) is a summary of legislative recommendations that the Office of Taxpayer Advocate (OTA) believes will strengthen taxpayers rights and improve tax administration. One of the Recommendations of the OTA is to

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If IRS wants to obtain records held in another country, Don’t ignore its request!

February 2018

At a certain point during an income tax examination, if the IRS determines that it needs documents or items located outside the U.S., it may issue a Formal Document Request (FDR) under the Internal Revenue Code Section 982 (IRC 982).  https://www.jdsupra.com/legalnews/if-irs-wants-to-obtain-records-held-in-47333/  

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Did FATCA Reporting help Catch Manafort and Gates?

January 2018

  • South Florida Legal Guide 2018 Annual Edition

BSA, FinCEN, Treasury and IRS Want to Know: Who is the Ultimate Beneficial Owner (UBO)?

January 2018

There seems to be a convergence by the Financial Crimes Enforcement Networks (FinCEN), the Treasury Department and the IRS for determining “who is the UBO” of entities.   The U.S. Government is determined to enforce financial transparency and combat the misuse of companies through

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Will Bankers = Law Enforcers on 5/11/18?

December 2018

On May 2016, FinCEN issued a “Fifth Pillar” of Customer Due Diligence (CDD) calling it the “CDD Rule”, which currently takes effect on May 11, 2018.   The CDD Rule applies to Covered Financial Institutions (federally regulated banks, federally insured credit

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Paradise Papers, Panama Papers…. The Message is Clear: Report Offshore Accounts!

November 2017

First, the Panama Papers, and now… the Paradise Papers.  The Paradise Papers contain the names of approximately 31,000 US citizens, including entities, or persons with US addresses.   The IRS and The Department of Justice will “harvest” the names in the

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US Persons and Financial Institutions: Beware when engaging financially with Venezuela

October 2017

On 8/25/17, President Donald Trump signed an Executive Order (EO) restricting and prohibiting certain transactions between US Persons and Venezuela.   The transactions that are prohibited by US Persons apply wherever a US Person is located. In addition, on 9/20/17, FinCEN

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New GTO covers Wire Transfers

October 2017

On August 22, 2017, FinCEN (Financial Crimes Enforcement Network) published a new Advisory regarding Geographic Targeting Orders (GTOs) covering residential real estate transactions in certain counties or boroughs of New York, Florida, California, Texas and Hawaii (newly added in this GTO).   The

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The OECD is focused on maintaining the integrity of the CRS

September 2017

As of August 2017, 102 international Jurisdictions are committed to the implementation timelines of the Common Reporting Standard (CRS).  There are 49 Jurisdictions that are committed to the first exchange during 2017 and 53 Jurisdictions for 2018.       https://www.jdsupra.com/legalnews/the-oecd-is-focused-on-maintaining-the-44072/  

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