On November 13, 2014, Hong Kong announced that it had signed a Model 2 FATCA IGA. Under the agreement Hong Kong financial institutions will enter into separate FFI agreements with the IRS and will report information on U.S. account holders directly to the IRS. Hong Kong indicated its intention to… – Continue reading
Should London’s Mayor pay U.S. taxes? How about filing FBARs and other forms that make it easy for the IRS to track his bank accounts? London’s Mayor Boris Johnson is English, but being born in New York means he’s American too. Turns out he never gave up his U.S. citizenship,… – Continue reading
The United States has treaty language that allows us to work with the taxing authorities in other countries to collect U.S. taxes owed from U.S. Citizens or their property located in those countries and to allow those countries to have IRS collect from their citizens or property located in the… – Continue reading
Earlier today, Treasury and the IRS issued yet another correcting amendment to the previously-issued regulations implementing the Foreign Account Tax Compliance Act (FATCA). FATCA become effective on July 1, 2014, and generally requires participating foreign financial institutions (FFIs) to begin reporting information regarding their U.S. account holders to the U.S…. – Continue reading
The New York Times’ report on prominent American think tanks receiving some $92 million from a minimum of 63 governments since 2011, prompted Rep. Frank Wolf (R-Va.) to ask Attorney General Eric Holder, a long overdue question: “Should think tanks be allowed to take undisclosed donations from foreign governments?” According… – Continue reading
November 18: The IRS, by releasing a transmittal message, noted that final versions of Form 1099-DIV and the related instructions for 2015 reflect the FATCA filing requirements for certain foreign financial institutions (FFIs). The instructions [PDF 181 KB] to Form 1099-DIV note that beginning in 2014, an FFI with a… – Continue reading
THE GOVERNMENT of Barbados is committed to the implementation of global standards for the supervision and regulation of the international business and financial services sector. This affirmation came today from Minister of Industry, International Business, Commerce and Small Business Development, Donville Inniss, prior to signing a Foreign Account Tax Compliance… – Continue reading
Fifty-one countries signed the Multilateral Competent Authority Agreement in Berlin on Oct. 29 to fight offshore tax fraud and evasion. The agreement aims to put an end to banking secrecy by sharing tax-related information with member states. Missing from the signatory list are the United States and China. China’s absence… – Continue reading
November 17: The Treasury Department and IRS today released for publication in the Federal Register a correction to a package of final and temporary regulations (T.D. 9657) issued previously in 2014 to harmonize the information reporting and withholding rules under chapters 3 and 61 of the Code to the regulations… – Continue reading
TAIPEI, Taiwan — The Financial Supervisory Commission’s (FSC, 金管會) chairman Tseng Ming-chung (曾銘宗) met with the U.S. treasury from Nov. 2 till Nov. 5 and signed an Intergovernmental Agreement (IGA) under the Foreign Account Tax Compliance Act (FATCA) that will see Taiwanese financial institutions directly providing 4,273 Taiwanese green-card holders… – Continue reading
The British Virgin Islands (the “BVI”) has now enacted legislation which allows for the implementation of its commitments under the Model 1B (i.e. non-reciprocal) intergovernmental agreements with the United States, signed on 30 June 2014, (the “US IGA”) and with the United Kingdom, signed on 28 November 2013, (the “UK… – Continue reading
Taipei, Nov. 13 (CNA) Taiwan’s financial authorities have found that there are 4,273 bank accounts in Taiwan whose holders are obligated to report assets to the United States tax authorities, Taiwan’s top financial regulator said Thursday. Tseng Ming-chung, chairman of the Financial Supervisory Commission, said most of the account holders… – Continue reading
IRS announces relief for accounts opened recently by non-residents aliens Jeffrey S. Freeman, J.D., LL.M notice on October 16, 2014 (Notice 2014-59, 2014-44 IRB) the IRS announced changes to the temporary regulations issued earlier this year under the Foreign Account Tax Compliance Act (FATCA). The changes provide relief from withholding… – Continue reading
The US Treasury has opened a new front in its war against offshore tax evasion. But for some it amounts to financial imperialism. Americans with legitimate bank accounts outside the country, and foreigners working in the United States, have begun receiving letters from their banks in Paris, Tokyo, Johannesburg and… – Continue reading
80 Percent View Derivatives Regulation and FATCA as Greatest Operational Challenges New York/London/Hong Kong/Singapore, November 11, 2014 – Increased regulatory requirements and related penalties, along with immature and fragmented data management processes are ranked as top concerns for financial firms in the management of client and legal entity data, according… – Continue reading
November 10: The IRS has posted a draft version (as of November 7, 2014) of Form W-9, Request for Taxpayer Identification Number and Certification, and a draft version of the instructions for a requester of Form W-9. Read the draft Form W-9 [PDF 109 KB] and the draft instructions [PDF… – Continue reading
Only a third of financial institutions now believe that their FATCA compliance efforts will now be completed within budget, according to a new survey by Thomson Reuters. Undermining the costs involved appears to be a common problem, with 27% of organisations surveyed saying that they expect their FATCA compliance spend… – Continue reading
The recent decision of the U.S.Tax Court, in Gerd Topsnik, (2014) makes it clear that an “informal” surrender of a Green Card, while recognized under immigration laws is not recognized for tax purposes. As stated in Checkpoint, ” The Tax Court held that because the taxpayer did not formally abandon… – Continue reading
If you have a bank account anywhere outside the U.S., chances are you will receive a letter saying that your bank must hand over the details of any American accounts, including yours. The letters vary with the country and with individual institutions. But the overall message is that the IRS… – Continue reading
November 10: The IRS has posted a draft version (as of November 7, 2014) of Form W-9, Request for Taxpayer Identification Number and Certification, and a draft version of the instructions for a requester of Form W-9. Read the draft Form W-9 [PDF 109 KB] and the draft instructions [PDF… – Continue reading
The US Treasury has opened a new front in its war against offshore tax evasion. Overseas banks are being ordered to cooperate with the US Treasury and help identify which of their customers might owe the government taxes – a move that some equate to a form of “financial imperialism,… – Continue reading
KUWAIT, Nov 8 (KUNA) — Senior commercial officer at the U.S. Embassy Dao Le said that Kuwait is a major partner especially in the field of energy, adding that Kuwait will maintain this position well into the medium term, as there is no other alternative for the US. Therefore, Kuwait… – Continue reading
The Internal Revenue Service (IRS) has added another 12,760 foreign financial institutions to the latest Foreign Account Tax Compliance Act (FATCA) list. The FATCA list is the US government’s definitive database of overseas financial institutions complying with the reporting tax information laws that started in July 2014. The current list,… – Continue reading
WASHINGTON: The United States Treasury has opened a new front in its war against offshore tax evasion. But for some it amounts to financial imperialism. Americans with legitimate bank accounts outside the country and foreigners working in the US have begun receiving letters from their banks in Paris, Tokyo, Johannesburg… – Continue reading
The US Treasury has opened a new front in its war against offshore tax evasion. But for some it amounts to financial imperialism. Americans with legitimate bank accounts outside the country, and foreigners working in the United States, have begun receiving letters from their banks in Paris, Tokyo, Johannesburg and… – Continue reading
FATCA compliance is going to cost more than anticipated, research has revealed More than half (55%) of financial organisations now expect to exceed their original budget to adhere to the new rules, while only 35% believe they will stay on budget, a survey from Thomson Reuters has found. The Foreign… – Continue reading
A source revealed that in order to settle the investigation into whether Bank Leumi Le-Israel (LUMI) BM helped Americans evade taxes, New York’s banking regulator will ask for over $300 million. The head of the state’s Department of Financial Services, Benjamin Lawsky, is looking for an amount that surpasses what… – Continue reading
The Writ Petition filed by the NDA Government in mid-October consists of two parts. The first part deals with the issue of Double Taxation Avoidance Agreement [DTAA], the information obtained from Liechtenstein through Germany and confidentiality obligations of Indian Government under the said DTAA. I had dealt extensively on this… – Continue reading
On October 27, the Indian government disclosed names of alleged tax evaders to the Indian Supreme Court in an affidavit signed by the Department of Revenue. The affidavit accused some of the country’s top business owners of tax evasion through foreign held bank accounts. This development raises questions over confidentiality… – Continue reading
The Bahamian government yesterday took a “critical step” in complying with the Foreign Account Tax Compliance Act (FATCA) by signing an intergovernmental agreement (IGA) with the U.S. During a press conference held at the Ministry of Financial Services, Minister of Financial Services Ryan Pinder stated that industry consultation represents the… – Continue reading
This publication provides a brief overview of the expected impact on entities incorporated in the British Virgin Islands (the “BVI”) of (a) the foreign account tax compliance provisions (“FATCA”) of the Hiring Incentives to Restore Employment Act, 2010 of the United States of America (the “US”); and (b) equivalent rules… – Continue reading
Financial Supervisory Commission Chairman William Tseng (曾銘宗) is leading a group of officials on a trip to the US in an effort to confirm details of the US’ Foreign Account Tax Compliance Act (FATCA) and to ink a tax treaty with Washington. Officials said Vice Minister of Finance Wu Tang-chieh… – Continue reading
(From left) Stephen Ross, Raghad Al-Khudhari, Kristin Konschik and Husain Al- Ghareeb KUWAIT: A child born in the United States, even taken out of the US after an hour or two after birth, is a US citizen and therefore subject to a recent tax law being implemented by the US… – Continue reading
It was anticipated that with Prime Minister Narendra Modi’s visit to the US, uncertainty over FATCA implementation would come to an end. However, the Indian government is yet to make any announcements on the FATCA implementation after giving an in-principle approval to FATCA Inter Governmental Agreement (IGA) -Model -1, few… – Continue reading
The Foreign Account Tax Compliance Act (“FATCA”) became law in March 2010. However, as with many things “government,” several extensions were provided for guidance and regulations to be promulgated. FATCA targets tax non-compliance by U.S. taxpayers with foreign accounts and focuses on the reporting: (1) by U.S. taxpayers about certain… – Continue reading
Union Finance Minister Arun Jaitley on Sunday said that the issue over the disclosure of the names of those who have illegally stashed their black money abroad is not a debate over the admission of confidential information but is a matter pertaining to the unauthorized expose of the names in… – Continue reading
London is an increasingly important hub for offshore law firms, which are winning business from City-based financial institutions, and clients in Russia, western Europe and sub-Saharan Africa. Offshore law firms are constantly evolving, it seems. Traditionally, they operated in one offshore territory: whether the British Crown dependencies of Jersey, Guernsey… – Continue reading
In a big setback to the IRS’s juggernaut against tax evasion and offshore accounts, a former top UBS banker has been acquitted of tax evasion. The U.S. charged Raoul Weil with conspiracy to defraud the U.S. government. The former exec was facing five years in prison and a $250,000 fine,… – Continue reading
Since the global economic crash of 2008, the Internal Revenue Service (IRS) in the U.S. has been trying to find other ways to generate income and much needed revenue. One avenue they are pursuing aggressively involves trying to stem tax evasion by U.S. citizens who are purposely hiding their funds… – Continue reading
Forty-one businesses across the three Crown Dependencies responded to the survey, with 78 per cent of respondents saying they have completed their FATCA classification and only 10 per cent reporting that their internal entities are not yet registered with the IRS. Confidence in FATCA compliance is high within the islands,… – Continue reading
Mark Hendrickson teaches economics at Grove City College. He writes the “No Panaceas” blog at Forbes.com and is a contributing editor of the St. Croix Review. Hendrickson’s most recent book is “God and Man on Wall Street: The Conscience of Capitalism” with Craig Columbus. The political left in America remains… – Continue reading
Finance ministers from more than 50 countries recently signed the Multilateral Competent Authority Agreement, with another 30 countries pledging to sign the agreement by 2018. The agreement, signed in Berlin, is an effort to end what the US Bank Secrecy Act, which they called “obsolete.” The ministers met for two… – Continue reading
With FATCA having been officially implemented for the most part this past July 2014, withholding agents will want to be especially vigilant in their duties and obligations regarding the solicitation and receipt of the appropriate Form W-8 from foreign persons. They will also want to be up on the rules… – Continue reading
NEW DELHI: The government’s ability to keep a secret could determine whether it will be able to sign a key accord with the US before the year-end deadline. It’s not just private capital flows that face the risk of higher withholding tax there if India is unable to sign the… – Continue reading
In one of the bluntest statements on the topic by any globalist thus far, controversial German Finance Minister Wolfgang Schäuble (shown) openly called for “global standards” and “global governance” in taxation to ensure that governments can continue extracting huge sums in taxes from the wealth-producing class in perpetuity. In an… – Continue reading
In the fight against tax evasion, member banks of the Association of Cyprus Banks (ACB) are currently in the process of implementing the Foreign Account Tax Compliance Act (FATCA), in anticipation of the upcoming intergovernmental agreement between the United States of America and Cyprus, ACB Director General Michael Kammas said…. – Continue reading
The Supreme Court on Wednesday virtually thwarted fresh attempts by the Modi government to go slow on the black money probe, citing “sovereign powers to sign treaties”. The court sternly asked the Centre to “just go whole hog to unearth the money”, leaving other worries to the Special Investigation Team… – Continue reading
Governments around the world closed in on tax evaders with an automatic data-sharing accord that broadens efforts by the U.S. and the five biggest European Union economies to more than 50 countries and territories. Finance ministers signed the agreement in Berlin today in a signal of global determination to capture… – Continue reading
New Delhi: A day after the Centre submitted its list of 627 Indians who have accounts in HSBC bank, Geneva for tax probe for suspected black money to Supreme Court, India has pulled out of multilateral information sharing agreement. The Mutilateral Competent Authority Agreement was signed by 51 countries in… – Continue reading
IRS Commissioner John Koskinen said in an interview last week that 2015 could present a very difficult filing season because of uncertainty about expired tax provisions and the implementation of new rules under the Affordable Care Act (ACA) and the Foreign Account Tax Compliance Act (FATCA). More than 50 provisions… – Continue reading
