Category: Internal Revenue Service (IRS)

UK opposes planned US dividend tax for offshore investors

The US government is facing calls to delay the introduction of a new tax on foreign investors in US equity-linked derivative transactions, after the G5 group of countries signalled their opposition and the US Securities Industry and Financial Markets Association (SIFMA) indicated its members would not be ready for the… – Continue reading


The Governments of the United States and Grenada have signed the Foreign Account Tax Compliance Act (FATCA) that will enforce a requirement for US citizens to file yearly reports on their non-US financial accounts. “This allows us to work together to ensure that financial institutions here in Grenada can help… – Continue reading

Microsoft agrees to more transparency on taxes in Australia

The Australian government is one of the most aggressive in highlighting the issue of multinational corporations avoiding taxes through extensive use of tax havens. Microsoft’s Australian subsidiary will start disclosing the amount of tax it pays in Australia, opting in to a government-transparency program aimed at shedding light on the… – Continue reading

Dumping Obama’s faux foreign tax legislation should be high on Trump’s to-do list

President-elect Donald J. Trump has stated that among his top priorities will be revocation of President Barack Obama’s misguided executive orders. Among the first such items to get the ax should be a series of legally infirm international agreements to implement a monstrosity unfamiliar to most Americans, called the Foreign… – Continue reading

13 IRS Tax Rules Trump Tax Plan Won’t Change

With Republican control of the House and Senate, President-elect Trump and Congress might tell the tax code, “you’re fired!” And as big as the coming tax changes might be, it’s worth noting what is highly unlikely to change. Keeping track of these 13 key tax rules could put dollars in… – Continue reading

Ukraine’s Cabinet of Ministers endorses draft agreement on FATCA with US

Ukraine’s Cabinet of Ministers has approved a draft agreement with the U.S. government to improve the implementation of tax rules and apply the provisions of the U.S. foreign account tax compliance act (FATCA). The decision is outlined in government resolution No. 821-r dated November 9, 2016 posted on the government’s… – Continue reading

IRS Nets $10 Billion FATCA Tax Haul

The US Internal Revenue Service (IRS) has netted more than $10 billion in secret offshore cash and investments. The controversial Foreign Account Tax Compliance Act (FATCA) has encouraged more than 100,000 taxpayers to reveal their overseas holdings. But the IRS suggests this is just the start as FATCA cranks up… – Continue reading

Cambodia on alert for US taxpayers

With the Internal Revenue Service (IRS), the tax-collection arm of the United States government, stepping up its global sweep to catch American individuals and corporations hiding their overseas earnings, the American Chamber of Commerce in Cambodia yesterday held a presentation for investors and financial institutions to make sure they are… – Continue reading

IRS Offshore Voluntary Compliance Tops $10 Billion

As international compliance efforts pass several new milestones, the Internal Revenue Service reminds U.S. taxpayers with undisclosed offshore accounts that they should use existing paths to come into full compliance with their federal tax obligations. Updated data shows 55,800 taxpayers have come into the Offshore Voluntary Disclosure Program (OVDP) to… – Continue reading

China Issues More Rigorous Advance Pricing Agreement Rules

China is requiring multinational groups to provide more information, including the location-specific advantages of their Chinese entities, when they apply for advance pricing agreements. The State Administration of Taxation’s Public Notice 64, dated Oct. 11 and released Oct. 18, requires companies to provide the additional information to Chinese tax authorities… – Continue reading

IRS, Mexico Reach Tax Deal For Contract Manufacturers

U.S. companies operating contract manufacturers in Mexico can avoid double taxation between the United States and Mexico under a deal struck between their respective tax authorities and unveiled Friday by the IRS. So-called maquiladoras can avoid double taxation through a unilateral advance pricing agreement signed with the Servicio de Administración… – Continue reading

US gives Trinidad new deadline for approving FATCA legislation

The United States is recommending that Trinidad and Tobago pass the Foreign Account Tax Compliance ACT (FATCA) by February next year, providing a five-month breathing space for the country. US Ambassador John Estrada in a brief statement issued from Washington said he wanted to provide an update on FATCA after… – Continue reading

Government, Opposition to meet on FACTA legislation

PORT OF SPAIN, Trinidad, Sept 10, CMC – Government and opposition legislators are to meet here on Monday as the deadline for meeting the September 30 deadline for passing the Foreign Account Tax Compliance ACT (FATCA). Caribbean financial executives have in the past bemoaned what they deem as an uneven… – Continue reading

Israeli government enjoined from disclosing personal account information to the IRS

One disadvantage of United States citizenship is that all income from whatever source, worldwide, is subject to taxation. This is true regardless of how one obtains American citizenship; indeed, there are many “accidental Americans” who, by dint of having been born to a person with American citizenship, are technically American… – Continue reading

How Amazon Values Its Tech Assets for Tax Purposes

Regulators in Europe and the US say that the value Amazon places on the technology behind user experience varies radically depending on which appraisal will lower its tax bill. Jeff Bezos’s relentless focus on user experience has helped him make Amazon the most valuable e-commerce company in the world. But… – Continue reading

IRS to Allow Voluntary Reporting of Global Tax, Profit

An IRS official said the agency is continuing its work on a mechanism to allow voluntary filings of country-by-country reports for companies required to comply with both the U.S. rules and those in a foreign country with an earlier effective date. “Actually being able to accept CBC reports for the… – Continue reading

«Delaware» Crackdown: All Bark and No Bite?

The U.S. has used judicial might to successfully pursue offshore tax cheats all over the world. A little-noticed new rule introduced by Barack Obama’s administration gets tough on U.S. states such as Delaware and Nevada, which are notorious for murky shelters often used for illicit purposes. But there is a… – Continue reading

ABA Pushes IRS On Taxation Of Cloud Transactions

The Section of Taxation of the American Bar Association (ABA) has written to the US Internal Revenue Service (IRS) saying that there is a pressing need for guidance from tax authorities due to the rapid growth of the cloud industry. The ABA noted that, although the Organisation for Economic Co-operation… – Continue reading

Undeclared incomes: Tax info-sharing agreements is a step in the right direction

Almost every country and every government now is fighting to detect undeclared Incomes and boost their tax collection. This could potentially help various countries show and collect large taxes from offshore accounts. The renewed thrust on automatic exchange of information (AEOI) between countries could achieve what seemed like a dream… – Continue reading

Feds Sue Facebook Over Ireland Asset Sale That Cut IRS Tax Bill

The U.S. Internal Revenue Service (IRS) said Facebook Inc. may have understated the value of intellectual property it transferred to Ireland by “billions of dollars,” unfairly cutting its tax bill in the process, according to court papers. The U.S. Justice Department filed a lawsuit on Wednesday in federal court in… – Continue reading

IRS inversion rules face blowback

A regulatory effort by the Obama administration to crack down on tax deals is facing backlash from business groups and lawmakers on both sides of the aisle. While the Internal Revenue Service (IRS) rules were intended to combat inversions — transactions in which a U.S. company combines with a foreign… – Continue reading

U.S. Treasury, IRS Move Quickly to Implement OECD BEPS Agreement, Finalizing Rule Requiring Country-by-Country Reporting by Multinationals

U.S. Companies Will Be Required to Disclose Relevant Financial Data on Country-by-Country Basis to Tax Authorities but not to Public WASHINGTON, DC – Today the U.S. Treasury and the Internal Revenue Service (IRS) published a rule, which will become final tomorrow, requiring the U.S. parent company of large, public and… – Continue reading

Assets agreement with US not quite ‘reciprocal’

Government most likely not to access bank data of Argentines in States despite deal As the whitewash bill is set to be approved this week, the government seeks to sign an assets deal with the United States to have access to data of the bank accounts of Argentines in the… – Continue reading

Death and Taxes: IRS Begins Procuring Offshore Client Accounts, Records from UBS

In what could be a significant development moving forward, UBS has provided the IRS with tax records and offshore accounts. UBS Group AG has come to an understanding with the US Internal Revenue Service (IRS), following a disagreement over client accounts in Singapore that had alleged tax evasion. The latest… – Continue reading

US plans reporting requirements for foreign-owned disregarded entities

US disregarded entities owned by foreign persons would be treated as domestic corporations under regulations proposed by the US Internal Revenue Service (IRS) on Friday (REG-127199-15). The new rules would apply for purposes of the reporting, record maintenance, and other compliance requirements that apply to 25% foreign-owned domestic corporations under… – Continue reading

Residence-Based Taxation Put Forward For Americans Abroad

With regard to the increasing talk in the US Congress on tax reform, American Citizens Abroad (ACA) has provided the House of Representatives Ways and Means Committee with a full reform proposal for the enactment of residence-based taxation (RBT) for American expatriates. ACA has said lawmakers should enact RBT instead… – Continue reading

US Court Dismisses Case Against FATCA Disclosures

The US District Court for the Southern District of Ohio has dismissed a case brought by Senator Rand Paul (R – Kentucky) and a group of individuals, who attempted to make several challenges to the Foreign Account Tax Compliance Act (FATCA) and the Report of Foreign Bank and Financial Accounts… – Continue reading

FATCA documentation for US-based trusts

Introduction Even though a trust may be established under the laws of a US state and have a US trust company serving as trustee (hereinafter a ‘US-based trust’), this does not mean that it is a US domestic trust for income tax purposes. If non-US persons make substantial decisions for… – Continue reading

Government looks to resolve 100 transfer pricing issues; seeks to sign more advanced agreements

In amove towards a more progressive taxation policy the revenue officials have set an aggressive target of resolving about 100 transfer pricing issues by signing advance pricing agreements (APAs) with multinationals this fiscal, people close to the development said. The government, through the Central Bureau of Direct Taxes (CBDT), had… – Continue reading

The Panama Papers And FATCA – Another Cover Up?

Tax avoidance on a grand scale is nothing new – the US President Barak Obama has led the way in tackling the issue head on with the Foreign Account Tax Compliance Act (FATCA) since 2010. FATCA demands non-American financial institutions should hand over details about accounts and investments controlled by… – Continue reading

Adventures in tax avoidance: Canada’s deep offshore tax haven connections

Much of the activity is legal, but it siphons away billions in tax revenue from government coffers The massive Panama Papers data leak shines a light not only on the dirty money being shuffled through tax havens, but also on the legal and common use of offshore accounts to significantly… – Continue reading

IRS Uses New Tactic to Expand Efforts to Combat Offshore Tax Evasion

In a search for financial records of a U.S. taxpayer who allegedly parked undeclared income offshore, the Internal Revenue Service (IRS) and the U.S. Department of Justice (DoJ) are seeking to enforce a summons against a U.S. branch of a foreign bank for records held by a foreign branch of… – Continue reading

Showdown looming over Singapore bank secrecy laws in UBS tax evasion case

NEWARK, NEW JERSEY (BLOOMBERG) – The US Internal Revenue Service (IRS) sought to make UBS Group turn over records on an account in Singapore held by a US citizen, setting up a showdown with the city-state over its bank-secrecy laws and potentially opening a new front against offshore tax evasion… – Continue reading

IRS Issues 2016 Non-Resident Withholding Tax Guide

The US Internal Revenue Service (IRS) has updated Publication 515, Withholding of Tax on Nonresident Aliens and Foreign Entities, which covers the obligations of the persons responsible for withholding tax (withholding agents). It is specified that the Publication is for withholding agents who pay income to foreign persons, including nonresident… – Continue reading

IRS Releases Dirty Dozen Scam List: Don’t be a Victim

Each year, people fall prey to tax scams. That’s why the IRS sends a list of its annual “Dirty Dozen.” Stay safe and be informed – don’t become a victim. If you get involved in illegal tax scams, you can lose money or face stiff penalties, interest and even criminal… – Continue reading

Cayman Islands: Getting Up To Date On FATCA – A Recap And Update

What is FATCA? FATCA refers to US legislation more fully known as the Foreign Account Tax Compliance Act and includes the US Treasury regulations implementing it. It was enacted as part of the Hiring Incentives to Restore Employment Act of 2010 (otherwise known as the, “HIRE Act”) on 18 March… – Continue reading

Secret accounts overseas urged to be reported

Those who have been hiding their income or wealth overseas had better think again, as Korea will soon be exchanging financial information with multiple countries, including tax havens. They are advised to voluntarily report it to the government before the end of March to be given a grace period, said… – Continue reading

IRS Still Hunts Offshore Accounts As More Foreign Banks Sign Deals With U.S.

With the web of FATCA information exchanges, whistleblowers, cooperating witnesses, and other sources, the IRS and Justice Department have a wealth of information at their disposal. They have warned offshore account holders to disclose before it’s too late. Under FATCA, banks everywhere want to know if you are compliant with… – Continue reading

IRS Adds More Foreign Banks To Disclosure Blacklist

The US Internal Revenue Service (IRS) has added more banks to the swelling list of financial institutions involved in tax avoidance. Customers of these banks owning up to past financial indiscretions under the Offshore Voluntary Disclosure Program (OVDP) face penalties based on balances over the past eight years. Penalties for… – Continue reading

Attorney sentenced to two years in prison for tax evasion

A Sacramento federal judge on Thursday sentenced a former West Sacramento attorney to two years in prison for a “sophisticated” tax-evasion scheme. According to prosecutors, James Stewart Richards, 69, owed federal income taxes between 1994 and 2003 totaling $170,000. Not only did he not pay taxes, but he went to… – Continue reading

Asia-Pacific financial institutions unprepared for FATCA and GATCA compliance

Best positioned firms will upgrade technology infrastructure Financial institutions across Asia-Pacific are behind the curve when it comes to being prepared for evolving global tax reporting regulations. That’s according to a recent survey by Wolters Kluwer Financial Services and the GRC Institute, which indicates that more than 90% of financial… – Continue reading

IRS: Banks Get More Time to Certify Accounts Under FATCA

Jan. 19 — Foreign financial institutions will have more time to certify whether their pre-existing accounts are owned by U.S. taxpayers under the Foreign Account Tax Compliance Act, the IRS said in Notice 2016-8. The Jan. 19 notice answers many significant questions raised by taxpayers on compliance with the law…. – Continue reading

QROPS – The Great American Pension Nightmare

The American dream can turn into a nightmare for expats wanting to switch their UK pensions to a Qualifying Recognised Overseas Pension Scheme (QROPS). Thousands of expats cross the Atlantic both ways with London home to Americans in sectors such as finance, entertainment and media, while Florida is a popular… – Continue reading