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India and US signed FATCA Agreement Today

9 July, 2015

India and the US today signed an agreement to implement the Foreign Account Tax Compliance Act (FATCA) that will facilitate exchange of information between the two countries starting on October 1, 2015. FATCA was signed

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India Expected to Sign FATCA Agreement Tomorrow

8 July, 2015

India is expected to sign an inter-governmental agreement (IGA) for the US tax compliance law Foreign Account Tax Compliance Act (FATCA) tomorrow. FATCA is aimed at combating possible tax evasion by Americans through financial entities

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Penalties for Form 5472 Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business

28 June, 2015

We would like to highlight a recent change in the IRS’ policy with respect assessing statutory late filing penalties related to certain international information forms. Of particular concern to international businesses is the revised policy

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Vatican Signs FATCA Agreement

28 June, 2015

Praying may not be enough for non-compliant taxpayers (or evaders) under the Foreign Account Tax Compliance Act (FATCA).  The Vatican has become the latest FATCA signatory to share bank information with the US. The Vatican

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Top 4 Exceptions to FBAR Filing Requirement

27 June, 2015

FBARs are due this week (again).  Below are the top 4 exceptions we often see for the FBAR filing requirement.  Certain Accounts Jointly Owned by Spouses – the spouse of an individual who files an

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Received a FATCA Letter from Your Foreign Bank?

24 June, 2015

If you have any US connections and have a non-U.S. bank account, you may have recently received a letter from your bank asking for your tax information. This may seem odd or new to you

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BE-10 Report: A New Overlooked International Reporting Form

21 June, 2015

The Bureau of Economic Analysis (BEA) is an agency of the U.S. Department of Commerce and is currently conducting a benchmark BE-10 survey which entails the filing of a BE-10 report by any U.S. person

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Educational Panel Discussion: The U.S. Government’s Global Crackdown on Tax Evasion: Where It Has Been and Where It Is Going

19 June, 2015

Last we spoke at a SABANA tax section bar association educational panel “The U.S. Government’s Global Crackdown on Tax Evasion: Where It Has Been and Where It Is Going” for attorneys in Orlando FL. Fellow

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Beware: IRS Reminds Taxpayers of FBAR Deadline

19 June, 2015

Last week, the Internal Revenue Service reminded all taxpayers with a filing requirement for a foreign bank account report to report their foreign assets by the June 30 deadline.  The IRS has been targeting FBAR

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New IRS Guidelines for Willful FBAR violations

6 June, 2015

Last week, the Internal Revenue Service released interim guidance (SBSE-04-0515-0025) on foreign bank account report (FBAR) penalties to improve the administration of the FBAR compliance program. The guidance contains amendments to the Internal Revenue Manual (IRM),

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New Much-Needed Guidance for Non-Willful FBAR violations

31 May, 2015

Last week, the Internal Revenue Service released interim guidance (SBSE-04-0515-0025) on foreign bank account report (FBAR) (also known as FinCen 114) penalties to improve the administration of the FBAR compliance program. The guidance contains amendments to

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Beware of U.S. tax consequences to a foreign trust with a U.S. beneficiary

27 May, 2015

There are many U.S. tax consequences to a foreign trust and a beneficiary of a foreign trust who is or becomes a U.S. citizen or resident alien. In this article it is assumed that the grantor

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