Deadline Notice: The Foreign Account Tax Compliance Act (FATCA) filing deadline for the Report of Foreign Bank and Financial Accounts, known as the (F...
Is there a DING knocking at your client’s door?
In 2013 the Internal Revenue Service (“Service”) issued several private letter rulings (“PLRs”) sanctioning the use of a state income t...
IRS: Supports Legitimate Captives but Warns Against Captives Lacking Substance
The Internal Revenue Service (“the Service”) annually publishes its Dirty Dozen list. The Dirty Dozen list compiles a variety of scams along wit...
Is it Time to Form Your Own Insurance Company?
Regardless of the business you run, there is risk. And the universe of risks applicable to your circumstance will differ (often wildly) from other bus...
DOJ Offers Swiss Banks a Deal
In 2013, The Justice Department (DOJ) announced a program that is designed to encourage Swiss banks to cooperate in their ongoing investigations of th...
IRS Starts Scrutinizing the Insurance Industry with Swiss Partners
In accordance with the DOJ Swiss Banking deal, Swisspartners, a group of Swiss asset management and life insurance companies (which, among its other i...
Credi Suisse Latest in Agreeing to Turn Over Information
Credit Suisse resolved its IRS investigation regarding certain banking practices that occurred with respect to U.S. taxpayers. The Credit Suisse resol...
FATCA’S New International Disclosure and a 30% Investment Income Tax Arrived July 1st
In 2010, Congress and President Obama carried into law the Hiring Incentives to Restore Employment Act (“HIRE Act”). The HIRE Act contained a set ...
IRS Voluntary Disclosure Program is Significantly Revised
The IRS initiated a new voluntary disclosure program for US taxpayers with foreign accounts on June 18, 2014. The IRS also noted some interesting stat...
New Changes to OVDP and Streamlined Procedure
Expanded streamlined procedures are now available to a wider population of U.S. taxpayers living outside the country and, for the first time, to certa...