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International Tax Law

The Countdown Begins as the IRS prepares to Release the First List of Approved Foreign Financial Institutions in Compliance with FATCA

The IRS recently issued Announcement 2014-17, providing an update on jurisdictions treated as having intergovernmental agreements (IGAs) with the United States in order to implement the Foreign Account Tax Compliance Act (FATCA). As of the date of the announcement,...

Fourth Circuit finds Fifth Amendment privilege inapplicable to documents required to be maintained under the Bank Secrecy Act

Last Friday, the Fourth Circuit Court of Appeals affirmed a district court's refusal to quash subpoenas related to foreign bank account records that were required to be maintained under the Bank Secrecy Act and Treasury Regulations.The case involves an investigation...

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