Category: Internal Revenue Service (IRS)
IRS changes procedure for reporting tax shelters
The Internal Revenue Service is temporarily allowing taxpayers who engage in so-called “reportable transactions,” typically tax shelters, to fax the Form 8886 for initially disclosing them to the IRS instead of mailing in the form. ... - Continue reading
Int’l task force sees success in cracking down on tax crimes
The tax crime-fighting group including the Australian Taxation Office (ATO, the Canadian Revenue Agency (CRA), the Dutch Fiscal Information and Investigation Service (FIOD), Her Majesty’s Revenue and Customs (HMRC) from the U.K. and the Internal Revenue Service Criminal Investigation Division (IRS-CI) from the U.S sees a silver lining regarding its purpose. ... - Continue reading
Tech companies rejected by top court on tax breaks
The U.S. Supreme Court refused to question a ruling that technology companies including Facebook Inc. and Google say will cost them billions of dollars in taxes by limiting deductions for stock payments to employees. The justices without comment Monday turned away an appeal by Intel Corp.’s Altera unit, which challenged… – Continue reading
Canada: U.S. Releases Anti-hybrid Regulations
The Internal Revenue Service (IRS) and U.S. Treasury Department have released anti-hybrid laws for offshore transactions. ... - Continue reading
First Look: US IRS publishes final and proposed regulations on hybrid mismatches
On the 8th of April 2020, the Internal Revenue Service (IRS) presented its laws on hybrid arrangements, which would strengthen its efforts against tax avoidance by multinationals. ... - Continue reading
US IRS publishes final tax regulations on dividend equivalents
Final tax laws published. ... - Continue reading
U.S. tax-filing requirements that Americans living in Canada should know
The Canada Revenue Agency (CRA) has sent the financial records of 900,000 dual citizens and Canadian residents to the U.S. Internal Revenue Service (IRS) for the 2018 year, according a recent news story. ... - Continue reading
A Run Through On Tax Evasion By Bitcoin Criminals
A report released by the Internal Revenue Service (IRS) has put quite some focus on Bitcoin’s scope for committing tax evasion ... - Continue reading
IRS touts 91% conviction rate for its 2019 tax crime cases
The Internal Revenue Service has a message for tax criminals: "We will not stop in our pursuit." ... - Continue reading
Indirect linkages to Tax Havens
According to the most current Federal Tax Compliance Research Report, there is an estimated US Net Tax Gap (Tax Not Collected) of $406 Billion. ... - Continue reading
RenTech’s Billion-Dollar Tax Cloud Darkens After IRS Ruling
A little-noticed decision by the Internal Revenue Service’s appeals unit may spell trouble for legendary investor Jim Simons, who’s embroiled in a multibillion-dollar tax dispute with the agency. ... - Continue reading
Nearly a million Canadian bank records sent to IRS
Number of government transfers of records of bank accounts held by Canadian residents to U.S. has been rising ... - Continue reading
Ukraine, U.S. ratify agreement on FATCA de-offshorization
The bill foresees that the Ukrainian banks will open information about the accounts of U.S. citizens in this country; Ukraine, on the other hand, will not be able to get the respective information about Ukrainian accounts in the States The Verkhovna Rada of Ukraine has passed the document about ratification… – Continue reading
US IRS addresses expiration of temporary section 385 debt/equity regs
The US IRS on October 11 released IRS guidance addressing the expiration of debt-equity documentation temporary regulations under code Section 385. ... - Continue reading
Accidental Americans’ sue France over FATCA disclosure rules
A group representing French-American taxpayers has filed a complaint against France with the European Commission over its compliance with the US Foreign Account Tax Compliance Act (FATCA), in a bid to avoid being blacklisted by French banks starting in January. France is a signatory to an agreement to give the… – Continue reading
FATCA blamed for one in five US expats planning to give up passport
One in five US citizens living abroad are on the verge of giving up their passports according to a survey published by US tax consultants Greenback. The Greenback survey – which was conducted by more than 3,000 US expats – studies the expat community’s opinions on taxation, citizenship renunciation, and… – Continue reading
IRS offers tax break to some American expats
The Internal Revenue Service (IRS) has outlined new procedures for some “accidental Americans,”, giving them the chance to comply with their US tax and filing obligations and in turn qualify for relief from back taxes, penalties and interest. The changes would allow people with less than $2m in net worth… – Continue reading
British citizens born in America face having bank accounts frozen
Tens of thousands of British citizens born in the US but only lived there for a few months or years face having their bank accounts frozen as part of a crackdown by the US tax authorities. The Internal Revenue Service (IRS) is ordering British banks to hand over the… – Continue reading
US appeals court sides with Amazon in $1.5 billion transfer pricing dispute
A US federal appeals court on Friday affirmed the Tax Court’s decision in Amazon, ruling that cost sharing buy-in payments made by Amazon’s Luxembourg subsidiary in exchange for Amazon’s transfer of intangible property should not include compensation for transferred residual business assets such as workforce in place, goodwill, and going concern value. ... - Continue reading
FATCA could push French banks to close up to 40,000 account
Banks in France have warned that they could be forced to close up to 40,000 accounts belonging to US citizens because of ongoing difficulties with the Foreign Account Tax Compliance Act (FATCA). ... - Continue reading
IRS to resume challenges to treatment of stock-based compensation in cost-sharing arrangements
The US IRS will once again examine allocations between group members of employee stock-based compensation in cost-sharing arrangements for transfer pricing purposes. ... - Continue reading
Seychelles Signs US FATCA Agreement
On July 3, 2019, the Seychelles Government announced that it has signed an intergovernmental agreement (IGA) with the United States to implement the requirements of the US Foreign Account Tax Compliance Act (FATCA). ... - Continue reading
First Look: US IRS issues final GILTI regulations, proposed DRD regs
Guidance on the final GILTI regulations ... - Continue reading
IRS To Probe Deeper Into Cost-Sharing Arrangements
Transfer pricing positions to be reviewed by IRS ... - Continue reading
United States: IRS Faces Big Decisions To Update The 482 Transfer Pricing Rules
It has been over a year since the Tax Cuts and Jobs Act (“TCJA”) was enacted. The transfer pricing rules set forth in the treasury regulations with respect to IRC Sec. 482 (“the Section 482 regulations”) have remained relatively unchanged since 1986. Nonetheless, multinational corporations doing business within the United… – Continue reading
US IRS begins FATCA crackdown
After years of deliberation and debate spanning two administrations, the Tax Information Exchange (United States of America) Bill, 2016, also known as the Foreign Account Taxpayer Compliance (FATCA) Bill was passed in the Senate on March 7, 2017. This following its unanimous passage in the House of Representatives, two weeks… – Continue reading
Court rules John Doe summons to identify law firm clients isn’t barred by attorney-client privilege
Section 7609(f) of the tax code allows the Internal Revenue Service to use a “John Doe” summons when the target is unknown. It has been used successfully by the IRS against banks and other financial institutions to find offshore accounts. Now, a district court in the Western District of Texas… – Continue reading
Welcome to Tax Hell, Little Earl of Sussex
Congratulations are in order to Prince Harry and Meghan, Duchess of Sussex, as they welcomed their yet unnamed son into the world yesterday. The new little Earl (he won’t get a Prince title like his cousins) weighed in at a healthy weighs 7lbs. 3oz and comes with a life long… – Continue reading
Tax information exchange updates
The Cayman Islands Department for International Tax Cooperation has updated the relevant dates for reporting under the Foreign Account Tax Compliance Act and the Common Reporting Standard. The reporting deadline for CRS and FATCA remains May 31. The department announced that the late filing of 2018 CRS and FATCA reporting… – Continue reading
Democrats introduce bill to curb tax havens
Rep. Lloyd Doggett, D-Texas, a member of the House Ways and Means Committee, and Senator Sheldon Whitehouse, D-R.I., a member of the Senate Finance Committee, introduced a pair of bills aimed at stopping corporations from using offshore tax havens and outsourcing jobs to other countries. The first bill, the No… – Continue reading
1.6 million Canadian banking records shared with IRS
CRA now transferring 600,000 banking records per year under controversial information sharing agreement The Canadian government has shared more than 1.6 million Canadian banking records with the U.S. Internal Revenue Service since the start of a controversial information-sharing agreement in 2014, CBC News has learned. In 2016 and again in… – Continue reading
IRS releases final rules on Section 965 repatriation taxes
The Internal Revenue Service and the Treasury Department issued final regulations spelling out how U.S.-based companies will have to pay repatriation taxes on offshore profits under Section 965 of the tax code. The IRS released proposed regulations on Section 965 in August, and the proposed rules went through a public… – Continue reading
IRS issues guidance on excess business loss limitations and NOLs
The IRS has issued guidance on excess business loss limitations and net operating losses following changes post-reform. The Tax Cuts and Jobs Act modified existing tax law by limiting losses from all types of business for non-corporate taxpayers. An excess business loss is the amount by which the total deductions… – Continue reading
IRS gives foreign banks a break in Trump tax law’s new levy
The Internal Revenue Service is giving foreign-based banks with U.S. operations some leeway when calculating a major new international tax aimed at preventing global companies from shifting profits abroad. Multinationals often transfer payments, such as interest or royalties, to their affiliates in low-tax jurisdictions to maximize deductions and minimize tax… – Continue reading
US DOJ charges four in ‘Panama Papers’ case
The United States Department of Justice has charged four people with crimes allegedly brought to light by the International Consortium of Investigative Journalism’s Panama Papers expose, according to a DOJ announcement published earlier this month. They are the first US criminal charges stemming from the ICIJ’s 2016 investigation, which reported… – Continue reading
New IRS offshore amnesty regime imposes bigger penalties for secret accounts
The US Internal Revenue Service (IRS) has issued guidance on the voluntary disclosure regime now in force, following the termination of its offshore predecessor on 28 September 2018. The new rules are effective for all disclosures after that date. And the possible penalties have gone up quite significantly. One of… – Continue reading
Cyprus: Approach Of Greek Authorities In Determining A Valid Foreign Proof Of Tax Residence
In Greece, an individual who has moved abroad must file an application to the local authorities in order to demonstrate a new address should they wish to change their status from resident to non-tax resident. Such an application is typically filed by March 10th of the year following the year… – Continue reading
