International Tax Law Archives - Page 16 of 26

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

Foodman website and JD Supra

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

Foodman website and JD Supra

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 (VDP). On

Foodman website and JD Supra

¿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

Foodman website and JD Supra

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

Foodman website and JD Supra

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

JD Supra and Foodman Website

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

JD Supra and Foodman Website

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

JD Supra and Foodman Website

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

Foodman CPAs & Advisors and JD Supra

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

Foodman CPAs & Advisors website and JD Supra

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

Foodman CPAs & Advisors

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