Category: IRS

Deal that sends Canadian bank records to IRS is ‘illegal,’ lawyer tells U.S. committee

Witnesses call for repeal of Foreign Account Tax Compliance Act An agreement that has resulted in hundreds of thousands of Canadian banking records being sent to the U.S. Internal Revenue Service could violate the U.S. constitution, a congressional subcommittee heard Wednesday. Testifying before a subcommittee of the House Committee on...

FATCA repeal on agenda of US Republicans

Washington’s Foreign Accounts Tax Compliance Act, known as FATCA, will be assailed afresh as lawyers and lobbyists renew efforts to repeal the law as part of President Donald Trump’s tax reform. Washington-based Jim Jatras, a Republican and co-leader of the Campaign to Repeal FATCA, says “lots is happening,” and his...

Transfer of Canadian banking records to U.S. tax agency doubled last year

Documents for thousands of Canadian residents transferred under controversial FATCA legislation Banking records of more than 315,000 Canadian residents were turned over to the U.S. Internal Revenue Service last year under a controversial information sharing deal, CBC News has learned. That is double the number transferred in the deal’s first...

HMRC withdraws 3,000 demands for upfront payment from those accused of tax avoidance

HMRC has withdrawn around 3,000 of its accelerated payment notices APNs – which give recipients 90 days to settle up – were introduced in July 2014 The Revenue has come underfire for issuing notices with ‘too little consideration’ HM Revenue & Customs has withdrawn around 3,000 of its controversial notices...

HMRC withdraws 3,000 demands for upfront payment from those accused of tax avoidance

HMRC has withdrawn around 3,000 of its accelerated payment notices APNs – which give recipients 90 days to settle up – were introduced in July 2014 The Revenue has come underfire for issuing notices with ‘too little consideration’ HM Revenue & Customs has withdrawn around 3,000 of its controversial notices...

Watchdog: IRS faces barriers in tax avoidance reviews

The Internal Revenue Service lacks a strong operation to audit a critical international tax compliance area, according to a watchdog report released Thursday. At issue is transfer pricing, a cost structure used by multinational companies to price goods and services they sell to subsidiaries in foreign locations. The IRS requires...

‘Israeli-Americans who did not do their tax homework at greater risk of penalties’

FATCA disclosure agreement takes effect, worrying some Israeli-Americans Dual American-Israeli citizens finally need to pay up. After years of the US Internal Revenue Service gradually baring down on American citizens living in Israel who evaded reporting income or paying taxes and numerous rounds of amnesty for those belatedly coming forward,...

Guyana formally agrees to share US persons’ bank account info with IRS

Guyana and the United States (US) on Monday inked an agreement, clearing the way for this country to share bank account information about American citizens and permanent residents with the US to help stamp out offshore tax evasion. “Today’s signing makes a significant step forward in our countries’ efforts to...

New Report Finds Corporate Offshore Tax Avoidance ‎a Growing Problem

According to a new report, secretive offshore tax avoidance practices are on the rise among multinational businesses. The report, released from the Financial Accountability and Corporate Transparency Coalition (FACT), finds that these practices put investors at risk because they are caught off guard when governments act to collect the lost...

Disingenuous Statements About Tax From Apple’s Tim Cook

Apple is a major part of why the United States is the world’s leading innovator on new technologies, particularly those involving telecommunications and computers. The company has over 66,000 domestic employees, and a large percentage of its customers are here — at least 40 percent, according to its latest annual...

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...

Panama Papers and US initiatives to identify entity beneficial owners

In early April 2016 files leaked from a large Panama-based law firm (known as the ‘Panama Papers’) brought to the attention of many the ways in which offshore companies and structures can be used to obscure the identity of beneficial owners, some of whom have used such entities to avoid...

IRS Proposes New QI Agreement for Foreign Banks to Comply with FATCA

The Internal Revenue Service has released new guidance on how foreign financial institutions can enter into a Qualified Intermediary agreement with the U.S. under the Foreign Account Tax Compliance Act, or FATCA. Notice 2016-42, released earlier this month, outlines the proposed QI agreement, which revises and updates the current agreement...

U.S. Corporate Tax Directors Have a Hard Time Adjusting to BEPS

Tax executives at U.S.-based multinational companies are having a hard time adjusting to the new rules demanded by the Organization for Economic Cooperation and Development’s Base Erosion and Profit Shifting plan, also known as OECD BEPS, according to a new survey. While OECD BEPS is not a requirement in the...

IRS Overlooks Noncompliance in Offshore Voluntary Disclosure Program

The Internal Revenue Service is missing out on imposing approximately $21.6 million in penalties on taxpayers who are denied entry or withdraw from its Offshore Voluntary Disclosure Program, according to a new report The report, from the Treasury Inspector General for Tax Administration, found the IRS needs to improve its...

CRA shared information on smaller bank accounts with IRS

Contrary to FATCA, accounts under $50,000 have been disclosed The Canada Revenue Agency has been transferring information about Canadian bank accounts worth under $50,000 U.S to the U.S Internal Revenue Service but cannot say how many accounts below that threshold have been shared with the Americans. Under a controversial information-sharing...

UK: Proposed Changes To The Non-Dom Regime From April 2017

The tax treatment of non-domiciled individuals is changing again from April 2017. The changes were first announced in the 2015 Summer Budget, and a Consultation document was issued in September 2015 setting out further details. The proposed changes target three key areas: The taxation of non-domiciled individuals who have been...

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...

Proposed IRS Country-by-Country Reporting Regulations: What Do They Mean for You?

Genesis of CbC Reporting and How it will Affect U.S. Multinational Enterprises Country-by-country (CbC) reporting is essentially exactly what it sounds like: a report that shows every country where a multinational enterprise (MNE) operates and allocates income, earnings and pays taxes. The CbC report regulations proposed by the Internal Revenue...

Private Eyes They’re Watching You – Offshore Planning after the Panama Papers

Overview If you have been reading my articles on JD Supra for a while, you will know that I love Afro-Cuban and Brazilian music. Nevertheless, the Hall and Oates song Private Eyes, is a more fitting song to describe the state of offshore planning in Tax Havens than “Oye Como...

Panama Papers Expose Celebs, Politicians, Billionaires With Offshore Tax Havens Despite FATCA

The Panama Papers–the biggest leak of financial data in history–has blown the lid off offshore tax havens, again. This time, those in the limelight include twelve current or former world leaders, many celebrities, and wealthy persons who are using offshore tax havens to hide their wealth. In scope, this is...

Warning: the IRS could file your return if you don’t, with troubling consequences

The tax world is clearly becoming more interconnected and globalized with countries exchanging financial information about each other’s citizens through FATCA or the upcoming Common Reporting Standard (CRS). Every international decision a taxpayer makes – whether or not he or she is residing in the U.S. – can trigger something,...

Implementation Status of US Foreign Account Tax Compliance Act (“FATCA”) in Malaysia

In March 2010, the FATCA was enacted in the United States (“US“) for the purpose of preventing the non-compliance of US persons with US taxation laws through the participation and cooperation of foreign governments and financial institutions. FATCA Implementation in Malaysia On 30 June 2014, Malaysia reached an agreement in...

AICPA Offers Recommendations to IRS on Country-by-Country Reporting

The American Institute of CPAs has written to the Internal Revenue Service recommending some changes in the IRS’s proposed regulations for country-by-country reporting by multinational corporations of financial information to curb tax avoidance. The proposed regulations were issued last December as part of an effort by the Organization of Economic...

Follow Ireland’s Example on Corporate Tax to Stop Inversions

Ireland’s 12.5 percent corporate tax rate has encouraged several major U.S. companies like Medtronic, Pfizer, Johnson Controls, and Baxalta to move there in tax inversions in recent months, saving them billions of dollars of taxes and protecting themselves from international competition in the process. The U.S. corporate tax rate, on...

How Other Countries Are Joining the U.S.’s Fight Against Offshore Tax Evasion

For the last five years, the U.S. has waged a strong battle against offshore tax evasion. In 2010, America began its boldest crackdown with the enactment of the Foreign Account Tax Compliance Act (known widely as “FATCA”). FATCA requires foreign financial institutions (e.g., banks, investment houses, etc.) doing business in...

IRS 80- Swiss Banks 0

The formal IRS/Department of Justice (DOJ) Swiss Bank Program has concluded with 80 Swiss banks coming forward. The banks agreed to provide information about personnel, depositors and advisors who were participated in or assisted U.S. taxpayers in offshore tax evasion. In addition to disclosure and cooperation with investigations each of...