Offshore Reporting
IRS to end Offshore Voluntary Disclosure Program in September
The Streamline Program Turns Two
The Streamlined Filing Compliance Procedure (SFCP) is now two years old. The SFCP was designed for taxpayers whose failure to […]
Automatic Information Exchange: Did the Dog Just Catch the Bus?
John Harrington recently published an article in Tax Notes Today (available through the Lexis paywall) regarding eight potential challenges presented by […]
IRS Issues PFIC Regulations: A New Start to an Old Beginning
On December 30, 2013, the US Treasury Department (the “IRS”) published a package of proposed, temporary, and final regulations relating […]
US Government Announces 6-Month Delay in Certain FATCA Rules
Recognizing the practical and logistical problems faced by US withholding agents and foreign financial institutions (“FFIs”), and the uncertainty faced […]
Changes Proposed to US Tax Reporting Rules for “Outbound” Transfers
On January 30, 2013, the US Treasury Department (IRS) proposed amendments to existing gain recognition agreement (“GRA”) regulations that apply […]
US Issues Final FATCA Regulations
On January 17, 2013, the US Treasury Department (IRS) released final regulations to implement the US reporting and withholding rules […]
IRS Updates FATCA Guidance
On October 24, 2012, the US Internal Revenue Service (“IRS”) issued Announcement 2012-42 along with a table (reproduced below) that […]
IRS Clarifies and Tightens New “Anti‑Inversion” Regulations
On June 7, 2012, the US Treasury Department (the “IRS”) issued new regulations interpreting the US tax rules that apply […]
US Treasury Department Issues Final “Bank Deposit” Interest Reporting Regulations
On April 17, 2012, the US Treasury Department released final regulations and a revenue procedure setting forth the requirements for […]
New Foreign Tax Credit Regulations Issued
On February 14, 2012, the US Treasury Department (“IRS”) published in the Federal Register regulations dealing with two separate but […]