¿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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Los Contadores Forenses son “Detectives Privados”

November 2019

El entorno actual de cambio creciente, las presiones económicas, la globalización, la tecnología, el gobierno corporativo, el cumplimiento y la complejidad de las transacciones financieras son las fuerzas impulsoras del inicio del fraude. Además, la desesperación económica, un solo evento

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Indirect linkages to Tax Havens

November 2019

The U.S. income tax system is based on the idea of voluntary taxpayer compliance. It is the taxpayer’s responsibility to report all reportable worldwide income. Some people attempt to evade paying taxes by failing to report all or some of

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An IRS “John Doe” Summons is a Powerful Weapon that can Puncture Attorney-Client Privilege

November 2019

An individual that provides information to an attorney may normally assume that the information provided to the attorney will be kept confidential under the attorney-client privilege.  That said, according to the Internal Revenue Manual (IRM), circumstances exist when attorney client

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Did you know that the IRS has 59 Compliance Campaigns? Have your Audit Plan Ready!

October 2019

IRS Large Business and International (IRS LBI) currently has 59 Active Compliance Campaigns.  The purpose of the IRS compliance campaign strategy is to redefine large business compliance work and build a supportive infrastructure inside the LBI.  The campaigns require strategic

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Automatic Exchange of Information leads to Deposit Drops at International Financial Centers

October 2019

On June 7, 2019, the Organisation for Economic Co-operation and Development (OECD) released a Memo which is a “summary of ongoing work to assess the impact of increasing tax transparency and exchange of information (EOI) on cross-border financial activity using

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Guilty from the Get-go in the IRS Updated Voluntary Disclosure Program?

September 2019

On June 20, 2019, the National Taxpayer Advocate (TA), an independent organization within the IRS that helps taxpayers and protects taxpayer rights, issued a final Report to Congress.  A section of the report focused on the TA’s request for the

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