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Archive for FATCA

Ending FATCA: Keith Redmond On The Harm Of FATCA And Universal Tax Jurisdiction

Keith Redmond

For this blog post, we bring an interview with Keith Redmond, a Multi-Cultural Global Management Executive working with cross cultural issues for over 20 years, who is currently the International Senior Consultant at Leaders Across Borders.

Keith is an American overseas, based in France. He has strong views about the harm of FATCA unfairly punishing a large group of Americans who are living overseas. He is fighting for these views by testifying in Congress in January.

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Exposé On The Cost For An Accidental American Under FATCA

William Byrnes

An interesting read by the Telegraph that walks an Accidental American through the process of renunciation of American citizenship to avoid paying a life time of US taxes, penalties, interest, and potentially criminal offences for non-filing. Read it here. Excerpts below:

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IRS Provides Legal Advice When Data Exchange With Foreign Countries is Confidential

Ronald Marini

In Legal Advice Issued by Associate Chief Counsel 2016-004, the IRS has given its opinion on the exact moment when information that it provides to and receives from foreign tax administrations via the Organization for Economic Cooperation and Development’s Common Transmission System becomes protected under the Code’s confidentiality rules. Legal Advice Issued by Associate Chief Counsel 2016-004.

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Is Form 8938 Required By “Green Card Holders” Who Are Nonresidents By “Treaty Tie Breaker”?

John Ricahrdson

The context: Form 8938 was created by the IRS to meet the reporting requirements mandated by Internal Revenue Code S. 6038D. S. 6038D was mandated by S. 511 of the HIRE Act.

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Singapore is Now Automatically Sharing Your Account Information!

Ron Marini

On July 25, 2016, we posted Tax Havens Coming Clean and Becoming Transparent where we discussed that the Inland Revenue Authority of Singapore has issued an e-Tax Guide on the territory’s general anti-avoidance rule in Section 33 of the Income Tax Act. The guide, issued on July 11, 2016, explains the three tests to determine whether the GAAR should apply.

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US – Israeli Dual Nationals Lose FATCA Challenge In Israel

Ron Marini

An Israeli Supreme Court panel has thrown out a challenge to a tax information-sharing agreement with the U.S. and removed a temporary block on FATCA’s implementation, rejecting arguments that the agreement violates the rights of Israelis.

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Extended Filing Requirements For IRS Form 5472

L S 8.4

On May 23, 2016, Internal Revenue Bulletin 2016-21 was released which proposes amendments to the regulations governing IRC 6038A.

The regulations are proposed to be applicable for taxable years ending on or after the date that is 12 months after the date these regulations are published as final regulations in the Federal Register.

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OVDP Is Not The Only Option For Taxpayers With Undisclosed Foreign Bank Accounts!

Ronald Marini

With the implementation of FATCA, the ongoing efforts of the IRS and the Department of Justice to ensure compliance by those with U.S. tax obligations have raised awareness of U.S. tax and information reporting obligations with respect to non-U.S. investments.

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Courts Not Sympathetic To FATCA Challenges!

Ron Marini

On September 30, 2015, we posted Judge Denies Injunctive Relief for FATCA Implementation!, where we discussed that an Ohio federal judge said that Senator Rand Paul, R-Ky., and others do not have standing in a challenge to the offshore financial account tax enforcement measures enacted in the Foreign Account Tax Compliance Act and they were not likely to succeed on the merits in the case. The case is Crawford v. U.S. Dep’t of Treasury, S.D. Ohio, No. 3:15-cv-00250, 9/29/15.

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New Pressure To Put On FATCA Countries To Comply

Ephraim Moss

Over the past several, years, the U.S. government has signed intergovernmental agreements (IGAs) with dozens of partner countries (83 altogether at latest count), which are designed to promote the implementation of the FATCA law requiring financial institutions (mainly banks and investment houses) outside the U.S. to report information on financial accounts held by their U.S. customers to the IRS.

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Cayman Islands—FATCA Reporting of American Depositors Has Been Postponed Again!

Ron Marini

Previously, we posted “Cayman Islands FATCA Reporting Of American Depositors Is Today!” The Cayman Islands has postponed the deadline for banks to report accounts of U.S. and U.K. persons for the 2015 tax year to the Cayman Tax Information Authority from August 10 to September 2 for both U.S. Foreign Account Tax Compliance Act reporting and U.K. Crown Dependencies/Overseas Territories reporting.

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Cayman Islands FATCA Reporting Of American Depositors Is Today!

Ronald Marini

Today, Wednesday, August 10, 2016 is the deadline for Cayman Islands financial institutions to complete their notification and reporting of American clients’ accounts to the Cayman Tax Information Authority, under the US Foreign Account Tax Compliance Act (FATCA).

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