Category: Internal Revenue Service (IRS)

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

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

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

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

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