Tax treaty tie-breakers
Under many US tax treaties, if a foreign individual is a tax resident of both the US and his home country then certain ‘tie breaker’ rules will apply to determine tax residence for treaty purposes.
Republican Party Rallies Against FATCA: Success Unlikely
The Republican Party is expected to approve a resolution calling for repeal of an Obama administration law that is designed to crack down on offshore tax dodging. In what would be the party’s first appeal
No More Delays for FATCA: Get Ready for Disclosure
The US Foreign Account Tax Compliance Act (FATCA) will definitely come into effect on 1 July this year with no possibility of further delay, according to officials of the US Internal Revenue Service (IRS). FATCA,
Canada and US sign FATCA tax deal where banks to share information with IRS
Ottawa and Washington have reached a compromise over how to apply a U.S. law targeting would-be American tax dodgers living in Canada. Canada has signed an agreement with the U.S. on the automatic sharing of
US DOJ Tax Asst Attorney General Keneally Reports that One third of Swiss Banks Joining US DOJ Swiss Bank Program
We have previously posted on the U.S. Justice Department’s program offered to Swiss banks and targeted to identifying U.S. taxpayers that have not disclosed foreign accounts to the IRS. It has now been stated that
Swiss Bank Disclosure Round Up
A host of Swiss banks have signaled their readiness to work with U.S. officials in a crackdown on wealthy Americans evading taxes. Many more are expected to follow in the coming weeks, as Switzerland’s cherished bank
More Swiss Banks Agree to Cooperate with the IRS
Lombard Odier & Cie and VP Bank (Switzerland) last week became the latest Swiss banks to say they would work with U.S. officials in a crackdown on lenders suspected of helping wealthy Americans evade taxes
U.S. Signs FATCA Pacts with Malta, Netherlands, Bermuda, Jersey, Guernsey and Isle of Man
Last week, the U.S. signed six more intergovernmental agreements with a half dozen jurisdictions, including several traditional offshore tax havens, to implement the Foreign Account Tax Compliance Act, or FATCA. Over the past week, the
Argue for No Penalty and a Warning Letter for FBAR Violations
The IRS may send a warning letter in lieu of asserting penalties for failure to file a Form TD F 90-22.1, “Report of Foreign Bank and Financial Accounts,” if it would be sufficient to bring
Swiss Banks are Pressuring Customers to Disclose
Swiss banks are pressuring current and former U.S. account holders to disclose undeclared assets to the Internal Revenue Service. In some cases, the banks are freezing accounts unless clients can prove they have declared the
US Department of Justice Encourages Swiss banks to Disclose Information
Last week the Tax Division of the Department of Justice strongly encouraged Swiss banks that want to seek non-prosecution agreements to resolve past cross-border criminal tax violations to submit letters of intent by the Dec.
Method to Cure Delinquent or Incomplete Foreign Information Returns Without Penalties
Last year, the IRS announced its third offshore voluntary disclosure initiative. Like the earlier initiatives, the 2012 OVDP is designed to encourage taxpayers with unreported offshore accounts and assets to voluntarily disclose them to the