Archive for tbeecher

Beneficial Ownership Registry for the Cayman Islands is Imminent!

On November 4, 2013, Wayne Panton, the Minister for Financial Services, Commented on the Commencement of Cayman’s Consultation on its G8 Action Plan.

On 31 October, the United Kingdom announced a proposal for a public register of beneficial ownership information, following the results of its public consultation. If implemented, the register conceivably would allow a citizen of any country to access information on the beneficial owners of UK-registered entities.

In the Cayman Islands, we also are assessing our regime on beneficial ownership. In our action plan on the misuse of companies and other legal structures, published immediately following the June G8 Summit, we committed to assess whether a central Read More

Written by | Posted in Caribbean • Europe, Middle East • OECD

Israeli Bank Client Pleads Guilty to Filing False Tax Return

The Latest in a Series of Defendants to be charged on Monday, January 14, 2013 with Concealing Accounts at Israeli Banks was a Beverly Hills resident. We originally posted The Long Arm of the IRS Reaches Israeli Shores – Oy Vey! which discussed that recent Articles about the IRS, FATCA and Israel, are proof that the IRS’ Probe into Secret Offshore Bank Accounts is not just limited to Switzerland.

Now Monajem Hakimijoo, also known as Manny Hakimi, of Beverly Hills, Calif., pleaded guilty on Feb. 13, 2014, in the U.S. District Court for the Central District of California to filing a false federal income tax return for tax year 2007, the Justice Department and Internal Revenue Service (IRS) announced Monday, February 17, 2014. Read More

Written by | Posted in Europe, Middle East • FATCA • FBAR • North America • Tax Fraud/Evasion/Crimes

IRS Warns of Heavy Call Volume and Offers Tips for Faster Answers

The IRS reminded taxpayers the Presidents Day holiday period typically marks one of the busiest weeks of the tax filing season for its phone lines. There are other alternatives to help taxpayers find answers to commonly asked tax questions.  TaxConnections has an “Ask Tax Questions” area of the site where Tax Professional Members reply to anonymous consumer’s tax questions.

The Internal Revenue Service has several easy-to-use, online tools on IRS.gov. Taxpayers can check the status of their refund, request a copy of their tax transcript or get an answer to their tax questions around the clock.

“The entire week of the Presidents Day holiday marks a peak time in the number of calls Read More

Written by | Posted in Income Tax • Individual • IRS

OECD Releases New Global Common Reporting Standard for Exchange of Tax Info!

The Organization for Economic Cooperation and Development released a new single global common reporting standard for the automatic exchange of information between tax authorities worldwide, intended to help fight cross-border tax evasion.

This document was approved and declassified by the Committee on Fiscal Affairs (“CFA”) on 17 January, 2014 and contains the global standard for automatic exchange of financial account information. It has been developed by the OECD, working with G20 countries, and in close co-operation with the EU.

• Part I contains the introduction to the standard and

• Part II contains the text of the Model Competent Authority Agreement (CAA) and the Read More

Written by | Posted in OECD

US Signed 22 FATCA Agreements – Unimpeded By Republicans!

The United States Treasury Department announced February 5, 2014 that Canada and Hungary will implement the Foreign Account Tax Compliance Act (FATCA), in an effort to discourage offshore tax evasion.

The Republican National Committee recently voted to call for the repeal of FATCA and plans to make it a campaign issue this year (see FATCA Implementation Unimpeded by Republicans!)

In an effort to alleviate the concerns of foreign governments about their own bank secrecy laws, the Treasury Department has been negotiating a series of intergovernmental agreements under which it also agrees to share information about their citizens and Read More

Written by | Posted in FATCA

New Reporting Obligations For Trustee And/Or Beneficiaries Related To Italians

The Milan law firm of Belluzo & Partners explain the new rule requiring Italian tax residents to disclose all assets held by a foreign trust of which they are a beneficial owner, regardless of the trust’s place of residence.

The rule, announced in Circular 38/E of 23 December 2013, takes effect in the 2013 tax year, and the deadline for reporting is 30 September 2014.

Such requirement holds for the “beneficial owner” of the assets located abroad and held directly or through companies, trusts and/or other arrangements (i.e. insurance wrappers).

The requirement refers to resident individuals and assimilated noncommercial entities Read More

Written by | Posted in Tax Provision/Tax Reporting

Why Is It That The IRS Seems To Always Receive Budget Cuts When They Produce The Most Revenue?

On January 17, 2014, President Barack Obama signed into law the omnibus appropriations bill to fund the government through fiscal year 2014, bringing Internal Revenue Service funding below its 2009 level! The Consolidated Appropriations Act (H.R. 3547) allocates $11.3 billion to the Internal Revenue Service, which is a $526 million decrease, or 4.4% decrease from the previous year.

This makes the Internal Revenue Service one of the biggest losers in the 2014 budget deal, since the service would get just $11.3 billion, which is $526 million below its 2013 budget and $1.7 billion less than President Obama requested and is lower than its 2009 budget. Read More

Written by | Posted in Federal • IRS

OECD Releases Draft of Radical Country-by-Country Reporting Template

The OECD has just published its draft of “A Model Template of Country-by-Country Reporting” that would require companies for the first time to provide tax administrations with exhaustive details of how they allocate their income, taxes, and business activities on a country-by-country basis.

On July 19, 2013 BEPS Action Plan, the OECD was directed to “develop rules regarding transfer pricing documentation to enhance transparency for tax administration, taking into account the compliance costs for business.

The rules to be developed will include a requirement that MNE’s provide all relevant governments with needed information on their global allocation of the income, economic Read More

Written by | Posted in OECD • Transfer Pricing

What’s New In The 2013 Form 1120-S?

The Internal Revenue Service has released a final version of the 2013 Form 1120-S, U.S. Income Tax Return for an S Corporation, and final instructions reflect what is new on as described below:

Form 1125-E, Compensation of Officers. For tax years beginning after 2012, use Form 1125-E if the S corporation deducts an expense for compensation for officers and has total receipts of $500,000 or more. See the instructions for lines 7 and 8.

New Schedule B-1 (Form 1120S), Information on Certain Shareholders of an S Corporation. S Corporations that check the “Yes” box for question 3 of Form 1120S, Schedule B, will need to complete new Schedule B-1 (Form1120S). See Schedule B-1 Read More

Written by | Posted in IRS • Tax Policy

221% Increase of US Expatriation

A record number of United States taxpayers renounced their citizenship or green cards in 2013, according to new data.

Each quarter the U.S. Treasury publishes the names of the Americans who officially expatriated during that period. In the last quarter of 2013, 630 people renounced their citizenship or relinquished their green cards, added to the previous 2013 quarters (2,369 people), bringing the total for 2013 to 2,999.

On Monday, May 14, 2012 we posted Facebook’s Co-Founder Just Defriended America, regarding Face book’s Co-Founder Mr. Saverin’s renouncing his U.S. citizenship ahead of the company’s IPO. Read More

Written by | Posted in Expatriate

IDR Enforcement Procedures Date of January 2 Postponed to March 3, 2014

Four days after we posted “Ready or Not… 2014 LB&I Information Document Request (IDR) Enforcement Process“, the Internal Revenue Service postponed the effective date to March 3, 2014.

The IRS Large Business and International (LB&I) Division announced that it will be extending the effective date of the enforcement procedures as outlined in the November 4, 2013 LB&I Directive on Information Document Requests Enforcement Process to March 3, 2014, to provide the clarification that is necessary to ensure that the procedures governing IDR issuance and enforcement are easily and clearly understood.

Kudos to the IRS for recognizing that the implementation of this procedure has issues Read More

Written by | Posted in Audit • IRS
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