Domestic Entity filers for tax year 2012 are not required to file Form 8938. The IRS anticipates issuing regulations in the future that will require a domestic entity to file Form 8938; but, until such regulations are issued, only individuals must file Form 8938....
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International Tax Law
Draft Form 8957, FATCA Registration Released
A draft of IRS Form 8957, which will be used to register financial instutions for FATCA, has been relased. To learn more, click here to view the IRS' announcement.
Seven Tips for Taxpayers with Foreign Income
The IRS reminds U.S. citizens and residents who lived or worked abroad in 2012 that they may need to file a federal income tax return. If you are living or working outside the United States, you generally must file and pay your tax in the same way as people living in...
IRS Revokes Voluntary Disclosure Status
In a move that could result in an end to IRS voluntary disclosure participants with offshore accounts, the IRS rescinded approval to participants who were previously granted inclusion in the voluntary disclosure program. Tens of thousands of taxpayers have...
FinCEN
The Financial Crimes Enforcement Network (FinCEN) has proposed changes to the FBAR to standardize it with other BSA electronically filed reports, add the capability for a third party preparer to file the report and record taxpayer identification numbers. To review the...
Swiss Bank Wegelin Sentenced to Pay almost $58 Million to the U.S for Conspiracy to Evade Tax
Yesterday, a U.S. court sentenced Swiss Wegelin & Co. to pay almost $58 million (on top of almost $16 million in forfeitures) for helping Americans evade taxes on $1.2 billion in Swiss accounts. In this historic first, the U.S. indicted a foreign bank and obtained...
U.S. Supreme Court Hears Oral Argument on Foreign Tax Credit Dispute
I've recently blogged about the plethora of multi-jurisdictional tax issues which continue to increase as business becomes ever more globalized. On February 20th, the U.S. Supreme Court yesterday heard oral argument in PPL Corp. v. Commissioner. In PPL, the Court is...
U.S. and Switzerland Sign Bilateral Agreement to Implement FATCA, Tax Compliance and Combat International Tax Evasion
The U.S. crackdown on tax evasion continues. On February 14, 2013, the U.S. Treasury Department announced that Switzerland and the United States have signed an agreement to make Swiss banks disclose more information about U.S. account holders.The agreement is the...
Is Israel the Next Switzerland?
As the Internal Revenue Service (IRS) and the criminal tax division of the U.S. Department of Justice (DOJ) expand the global scrutiny of offshore bank accounts, they have turned their attention on three of Israel's biggest banks: Bank Leumi Le-Israel, Bank Hapoalim...
International Agreements Abound to Fight Offshore Evasion
From Argentina to the United Kingdom, and places in between like India, Israel, Korea, New Zealand, Singapore, Bermuda, Brazil, the BVI and Check Republic, the Treasury Department announced today that it is engaged with over 50 countries and jurisdictions worldwide to...
