In response to Executive Orders requiring a broad federal review of existing regulations, Treasury and IRS issued this morning proposed regulations easing certain compliance burdens imposed on foreign financial institutions and withholding agents by the Foreign Account Tax Compliance Act (FATCA) regime.
The proposed regulations would eliminate withholding on payments of gross proceeds, defer withholding
Today the IRS published a reminder to foreign financial institutions and their compliance officers that certifications required by the Foreign Account Tax Compliance Act (FATCA) are due no later than December 15, 2018. This is the first compliance certification deadline under the FATCA reporting regime, which became fully effective as of July 1, 2014. Institutions
On December 12, 2018, Matthew D. Lee will participate in a ABA Tax Section webinar entitled “Transparency Tide or Tsunami? The New Wave of Global Reporting Rules and IRS Tools To Unearth Foreign Financial Accounts.” This webinar will address the latest developments with respect to the foreign financial asset reporting rules and recent offshore tax
On September 29, 2018, the Internal Revenue Service closed for good the long-running Offshore Voluntary Disclosure Program (OVDP), its hugely successful tax amnesty program for undisclosed offshore financial assets. Since March 2009, the IRS has maintained an offshore voluntary disclosure program in some form or fashion, and more than 56,000 taxpayers have taken advantage of
In a move sure to send shock waves through the offshore banking community, the Justice Department yesterday announced its first criminal conviction for violating the Foreign Account Tax Compliance Act (FATCA). Adrian Baron, the former Chief Business Officer and Chief Executive Officer of Loyal Bank Ltd, an offshore bank with offices in Budapest, Hungary and
Fox Rothschild LLP Partner Matthew D. Lee recently authored an updated version of the Foreign Account Tax Compliance Act Answer Book, published by Practising Law Institute. Lee’s book provides a detailed analysis of the international tax compliance regime imposed by the Foreign Account Tax Compliance Act and its impact on foreign financial institutions, withholding agents
The Internal Revenue Service has issued its annual reminder to taxpayers that they report their foreign assets on their individual tax returns due on April 17, 2018. Individuals with offshore assets such as bank accounts generally have up to three reporting obligations with respect to such assets. First, individuals with foreign bank accounts must answer
The Foreign Account Tax Compliance Act (FATCA) requires a foreign financial institution to appoint a “Responsible Officer” who is obligated to submit periodic compliance certifications to the Internal Revenue Service attesting to the institution’s compliance with various FATCA duties. For most Participating Foreign Financial Institutions (FFIs) and Reporting Model 2 FFIs, the first deadline for
In the midst of the tax reform debate currently embroiling Congress, Senator Rand Paul (R-Kentucky) has introduced an amendment seeking to repeal the Foreign Account Tax Compliance Act (FATCA), an anti-tax evasion law enacted in 2010 that requires foreign banks to annually disclose to the Internal Revenue Service the identities of their U.S. customers, or
Tomorrow morning (November 17) the International Consortium of Investigative Journalists (ICIJ) is set to release publicly the first set of comprehensive data from the recent “Paradise Papers” leak. The initial data will include information on approximately 25,000 offshore entities and trusts registered in more than 30 jurisdictions, primarily from client records of the Appleby law