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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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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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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¿Qué sucede si una FFI pierde su GIIN?

May 2020

Para estar registrado en FATCA y exento de retención por parte de los agentes de retención de los Estados Unidos, una institución financiera extranjera (“FFI”) debe de tener un número de identificación de intermediario global (“GIIN”). Una institución financiera extranjera

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What happens if an FFI loses its GIIN?

May 2020

In order to be FATCA registered and exempt from withholding by U.S. withholding agents, a Foreign Financial Institution (FFI) must have a Global Intermediary Identification Number (GIIN).   A Foreign Financial Institution withoutaGIIN is treated as unregistered in FATCA and faces

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FBAR Penalties: Is it per Account or per Violation?

February 2020

U.S. Taxpayers (includes a citizen, permanent resident, corporation, partnership, limited liability company, trust and estate) are required to file a Report of Foreign Bank and Financial Accounts (FBAR) if they have: a financial interest in or signature or other authority

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Are there conflicting signals from IRS as it relates to Section 965?

February 2020

IRC Section 965 (Treatment of Deferred Foreign Income Upon Transition to Participation Exemption System of Taxation) was part of the TCJA enacted on December 22, 2017.  The sections requires a United States shareholder to pay a transition tax on the

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IRS issues FATCA Relief but not for All

January 2020

On September 6, 2019, IRS announced Relief Procedures for Certain Former Citizens.  These are procedures for certain persons who have relinquished, or intend to relinquish, their United States  citizenship, who wish to come into compliance with their U.S. income tax

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IRS “BEEFS UP” Section 965 COMPLIANCE for 2017 and 2018 Returns

November 2019

On July 2, 2018, the IRS introduced a Compliance Campaign directed at Section 965 (Transition Tax) of the Internal Revenue Code (IRC).  In its original launch, the Section 965 Campaign stated that U.S. shareholder are required to pay a “transition

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