Archive for tbeecher

IRS And Treasury Department to Amend Definition of Shareholder of A PFIC

In Notice 2014-28, 2014-18 IRB, IRS has announced that it will amend the regs under Code Sec. 1291 to provide that a U.S. person that owns stock of a passive foreign investment company (PFIC) through a tax-exempt organization or account will not be treated as a shareholder of the PFIC. Code Sec. 1291 imposes a special tax and interest charge on a U.S. person that is a shareholder of a PFIC and receives an excess distribution (defined in Code Sec. 1291(b) from the PFIC or recognizes gain derived from a disposition of the PFIC that is treated as an excess distribution under Code Sec. 1291(a)(2). Code Sec. 1298(a) sets forth attribution rules that treat a U.S. person as the owner of PFIC Read More

Written by | Posted in IRS • Treasury Regulations

FATCA Picking Up Momentum And US Gives Foreign Banks More Time to Register

Under the Foreign Account Tax Compliance Act (FATCA), foreign banks, insurers and investment funds must send the Internal Revenue Service information about Americans’ and U.S. permanent residents’ offshore accounts worth more than $50,000. Institutions that fail to comply could effectively be frozen out of U.S. markets.

“Since the 2012 release of the Model 1 and Model 2 intergovernmental agreements (IGAs) to implement the Foreign Account Tax Compliance Act (FATCA), there has been robust and growing interest from jurisdictions worldwide to enter into IGAs. To date, the United States has signed IGAs with 26 jurisdictions and has reached agreements in substance or is in advanced discussions with many others. Read More

Written by | Posted in FATCA

IRS Reminds Those with Foreign Assets of U.S. Tax Obligations

The IRS reminds United States citizens and resident aliens, including those with dual citizenship who have lived or worked abroad during all or part of 2013, that they may have a U.S. tax liability and a filing requirement in 2014.

The filing deadline is Monday, June 16, 2014, for U.S. citizens and resident aliens living overseas, or serving in the military outside the U.S. on the regular due date of their tax return. Eligible taxpayers get one additional day because the normal June 15 extended due date falls on Sunday this year. To use this automatic two-month extension, taxpayers must attach a statement to their return explaining which of these two situations applies. See U.S. Citizens and Resident Aliens Abroad for details. Read More

Written by | Posted in Expatriate • FBAR • IRS

NOW Swiss Bank Information Can Be Disclosed To Foreign Tax Authorities WITHOUT Notice!

We previously posted “Your Swiss Bank Info Is Being Transferred To The US Government As We Speak!… This Is Not An April Fools Joke!” on Wednesday, April 2, 2014, where we discussed that The United States Justice Department has received 106 requests from Swiss entities to participate in a settlement program aimed at ending a long-running probe of tax-dodging by Americans using Swiss bank accounts according to a senior US official.

These banks will have to disclose a great deal of information about their American clients, even including some of their names by April 30, 2014!

To make matters worse for US tax dodgers… if that is even possible… Swiss Parliament has approved a legal amendment that tax evaders will not always have to be told if Switzerland Read More

Written by | Posted in FATCA • OVDP • Tax Fraud/Evasion/Crimes

Your Swiss Bank Info Is Being Transferred To The US Government As We Speak! … This Is Not An April Fools Joke!

We originally posted Tuesday, January 28, 2014 “Offshore Swiss Bank Account? This May Be Your Last Chance To File A Voluntary Disclosure!,” where we discussed that The United States Justice Department has received 106 requests from Swiss entities to participate in a settlement program aimed at ending a long-running probe of tax-dodging by Americans using Swiss bank accounts according to a senior US official.

On August 29, 2013, we previously posted “Swiss Banks Agree to Plan to End Past US Tax Evasion Issues!“, where we discussed that Swiss banks were ready to pay hefty fines for sheltering United States tax fugitives under the terms of a new deal given the green light by the Swiss government. Read More

Written by | Posted in IRS • OVDP

IRS Targets Americans Living In Israel!

According to Jewish Daily Forward, this upcoming tax season could entail some unpleasant surprises for United States citizens who either live in Israel or who hold bank accounts there.

Filing requirements for these Americans have become more rigorous and the odds of being audited by the Internal Revenue Service are higher than they’ve ever been. In fact, tax accountants working in Israel estimate that almost every American expatriate living in Israel and filing for a child tax credit in their annual return can expect an audit.

“I’ve seen more audits in the past year or two than I’ve seen in the previous 30 years combined,” said Philip Stein, an American CPA working in Israel. “It created a difficult atmosphere both for honest tax preparers and for honest families filing their returns.” Read More

Written by | Posted in Europe, Middle East • Expatriate • IRS

Caterpillar Saved Billions In US Tax By Shifting Profits To A Swiss Subsidiary

An American manufacturing icon, Caterpillar Inc., used a wholly owned Swiss affiliate to shift $8 billion in profits from the U.S. to Switzerland to take advantage of a special 4 to 6 percent corporate tax rate it negotiated with the Swiss government and defer or avoid paying $2.4 billion in U.S. taxes to date, a new report from Sen. Carl Levin, the chairman of the U.S. Senate Permanent Subcommittee on Investigations shows.

“Caterpillar is an American success story that produces phenomenal industrial machines, but it is also a member of the corporate profit-shifting club that has shifted billions of dollars in profits offshore to avoid paying U.S. taxes,” Levin said. “Caterpillar paid over $55 million for a Swiss tax strategy that has so far enabled it to avoid paying $2.4 billion in U.S. taxes. That tax strategy depends on the company making the case that Read More

Written by | Posted in Corporate • Tax Fraud/Evasion/Crimes

IRS Released Revised Form W-8BEN-E For Entities

Earlier, we posted “IRS Revised Form W-8BEN For Individuals – What Form Do You Use For Entities?” Where we discussed that the Internal Revenue Service (IRS) had released revised IRS Form W-8BEN (Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding (Individuals)).

The IRS Instructions for Form W-8BEN provided that Form W-8BEN IRS Form W-8BEN is now used exclusively by individuals and Entities should use IRS Form W-8BEN-E which was still in draft form.

We advised that taxpayers should use the old W-8BEN for entities, until the new one (coming out soon) for entities, W-8BEN-E comes out. Well the new Form W-8BEN-E has Read More

Written by | Posted in FATCA • IRS

IRS Revised W-8BEN For Individuals – What Form Do You Use For Entities?

The Internal Revenue Service has released revised IRS Form W-8BEN (Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding (Individuals)). The IRS has also released revised IRS Instructions for Form W-8BEN .

Generally, certain foreign persons are required to provide IRS Form W-8BEN to their withholding agents or payors with regard to certain income payments, including fixed or determinable annual or periodical income (FDAP income) from US sources, in order to:

• Establish that such persons are not US persons;

• Claim that they are the beneficial owners of the payments; and Read More

Written by | Posted in IRS

You May Want to Make Your Voluntary Disclosure NOW If You Are A Credit Suisse Client

On Monday, March 10, 2014, we posted United States Client of Credit Suisse? Last Chance To File A Voluntary Disclosure! where we discussed that Thousands of Credit Suisse Group AG’s United States clients still don’t know whether tax authorities will learn their identities as prosecutors work to conclude a three year probe of how the bank helped them evade taxes.

The Swiss disclosure program will lead to 106 banks’ producing information short of client names. We posted on January 28, 2014, Offshore Swiss Bank Account? This May Be Your Last Chance To File A Voluntary Disclosure! where we discussed that the United States Justice Department has received 106 requests from Swiss entities to participate in a US settlement program. Read More

Written by | Posted in OVDP

Are You Kidding Me? Weil Ex-UBS Chief Pleads Not Guilty to US Tax Charges

We previously posted on December 16, 2013, The Second Ex-UBS Banker is About to Blow The Whistle on His US Clients! where we discussed that the former head of UBS’s wealth management division, Raoul Weil, has agreed to be extradited to the United States to face charges and U.S. Magistrate Judge Patrick Hunt agreed to let Weil stay with friends in New Jersey after putting up the bond, which included $9 million in a personal surety by Weil, $500,000 from the New Jersey family and the other $1 million a corporate surety bond signed with a bail bondsman.

United States authorities issued an international arrest warrant for Weil in early 2009, just months after he was charged with allegedly conspiring to help 17,000 American clients of Swiss bank UBS avoid taxes. Read More

Written by | Posted in Tax Fraud/Evasion/Crimes

United States Client of Credit Suisse? Last Chance To File A Voluntary Disclosure!

Thousands of Credit Suisse Group AG’s United States clients still don’t know whether tax authorities will learn their identities as prosecutors work to conclude a three-year probe of how the bank helped them evade taxes.

We posted on February 27, 2014, Report to Congress: Credit Suisse Help US Taxpayers Hide Billions in Offshore Accounts! where we discussed the Permanent Subcommittee on Investigations (PSI) of the United States Senate held a hearing, “Offshore Tax Evasion: The Effort to Collect Unpaid Taxes on Billions in Hidden Offshore Accounts,” on Wednesday, February 26, 2014.

The PSI hearing’s stated purpose of continuing the PSI’s examination of tax haven bank Read More

Written by | Posted in OVDP • Tax Fraud/Evasion/Crimes
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