The OECD is focused on maintaining the integrity of the CRS
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. The OECD is
- JD Supra
FATCA, FCPA, AML and OFAC allow the US to regulate the world. But what does it really mean?
In the current environment of increased regulation, transparency, reporting and heightened compliance standards, the US and its Government Agencies have an arsenal of tools with extraterritorial application. Following is FATCA, FCPA, AML and OFAC: FATCA: requires Foreign Financial Institutions to
- JD Supra
Are you a Taxpayer identified by IRS for not Reporting Offshore Financial Assets?
Taxpayers with unreported foreign financial assets and income run the risk of having the Government determine if their conduct was willful or non-willful. The definition of “Willful” or “non-willful” in Taxpayer’s conduct makes a big difference in how civil or
- JD Supra
Did you know that Form 8938 filing obligations apply to Specified Domestic Entities?
A US Person that owns US entities like corporations or partnerships that conduct cross-border business may have a Form 8938 (Statement of Specified Foreign Financial Assets) filing obligation. IRS defines Specified Individuals as: US citizens Resident Aliens of the US
- JD Supra
Do you know about FATCA international payments?
Do you know about FATCA international payments? was published by the South Florida Legal Guide.
- South Florida Legal Guide/Miami Herald Business Monday
Why you need EXPERT ADVICE if you have a PFIC and you are out of Compliance!
Taxpayers need to rely on the expert professional advice of a tax specialist for the treatment of Passive Foreign Investment Companies (PFICs) during Offshore Voluntary Disclosure Program (OVDP) reporting. PFIC computations are challenging for a Taxpayer in an amnesty program
- JD Supra
FBAR Penalty Amounts are in the “Best Judgement” of an IRS Examiner
The Report of Foreign Bank and Financial Accounts (FBAR) is not a tax form. Its filing is not required by the Internal Revenue Code. It is required by Title 31 of the Code of Federal Regulations. Title 31 is the
- JD Supra
International Noncompliance
International Noncompliance was published by the South Florida Legal Guide.
- South Florida Business Journal Supplement to the Miami Herald Business Monday
Do You know that the US might have a Tax Sharing Information Agreement with your Country?
The US has Tax treaties and Tax Information Exchange Agreements (TIEAs) with certain countries that provide, upon request, for the exchange of U.S. income information regarding their citizens or residents. There are currently 43 countries on the list. Exchange of
- JD Supra
Traps for the Unwary: Are Financial Institution receiving adequate FATCA consulting and training?
FATCA is Chapter 4 of the Internal Revenue Code (IRC). It conscripts Foreign Financial Institutions (FFIs) to act as reporting and withholding agents for the U.S. Government. To enforce its conscription, it contains a mechanism for financially penalizing FFIs that
- JD Supra
US Banks wanting to be ahead of the FATCA game must master international tax compliance
The terms FDAP (Fixed, Determinable Annual and Periodical Income) and ECI (Effectively Connected Income) are expansive terms. They are the backbone behind the tax withholding, and reporting requirements imposed on US Banks with respect to outbound payments. Many of the
- JD Supra
The U.S. a tax haven? Could be questionable going forward given the new scrutiny of disregarded entities……
The U.S. a tax haven? Could be questionable going forward given the new scrutiny of disregarded entities…… was published by the South Florida Legal Guide.
- Miami Herald Business Monday - South Florida Legal Guide Supplement
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