International Tax Law

On Friday, October 2, 2015, the Internal Revenue Service ("IRS") announced the exchange of financial account information with certain foreign tax administrations, meeting a key Sept. 30 milestone related to FATCA, the Foreign Account Tax Compliance Act.The IRS...

Once again, the Department of Justice has flexed its muscles and shown dishonest financial professionals that if they help clients hide assets offshore or create sham entities for clients to evade taxes, they will be prosecuted. The tax preparers in this case helped...

In the past two weeks, three Swiss banks--Bank Linth LLB AG (Bank Linth), Bank Sparhafen Zurich AG (BSZ), and Ersparniskasse Schaffhausen AG (EKS)-have reached resolutions under the Department of Justice's Swiss Bank Program. The Swiss Bank Program, which was...

For those with one or more bank of financial accounts located outside the United States, or those who have signature authority over such accounts, Report 114, Report of Foreign Bank and Financial Accounts is due Tuesday, June 30, 2015. For more information, see the...

In a recent edition of TaxTips, the IRS reminds taxpayers of pending deadlines related to foreign income and assets. All U.S. citizens and residents must report worldwide income on their federal income tax return. If you lived outside the U.S. on the regular due date...

After helping taxpayers hide assets in offshore bank accounts for more than 10 years, Bank Leumi entered into an agreement with the Department of Justice in which it will pay the United States $270 million as a penalty and will make a full and complete disclosure of...

After years of investigation by U.S. law enforcement authorities, and a plea of guilty for conspiracy, Credit Suisse AG was sentenced on November 21, 2014 for conspiracy to aid and assist U.S. taxpayers in filing false income tax returns and other documents with the...

Those FI's seeking to obtain QI status to be effective for the calendar year 2014 must submit their Form 14345 and Form SS-4 no later than the close of business December 5th, 2014. All applications received after that date will be effective for calendar year 2015.

Owners of Canadian retirement plans received good news today when the IRS announced that taxpayers with registered retirement savings plans (RRSPs) and registered retirement income funds (RRIFs) will now automatically qualify for tax deferral similar to that available...

A federal jury found that Carl Zwerner must pay more than $2 million for wilfully failing to file Reports of Foreign Bank and Financial Accounts (FBARs). In this case, the IRS sought a 50 percent penalty for each of the four years at issue, for a total of 200 percent...