The Department of Justice (DOJ) announced that banker Adrian Baron of Loyal Bank Ltd. pleaded guilty to “conspiring to defraud the United States by failing to comply with the Foreign Account Tax Compliance Act (FATCA). According to court documents, Mr. Baron conspired with an undercover agent to conceal the undercover agent’s ownership of accounts opened…
DetailsThe IRS recently released a reminder that taxpayers have until September 28, 2018 to apply for the OVDP. While the Streamlined Filing Offshore Procedure (SFOP), Streamline Domestic Offshore Procedures (SDOP) and Delinquent International Information Return (DIIR) programs remain open, the OVDP is the only program to reduce penalties and avoid potential criminal sanctions for persons…
DetailsThe article was first published in Global Tax Weekly, issue 170. Below is the full text of the seventh article in the series on US taxes for US persons living outside the US. US Tax Compliance And Planning For US Executives, Entrepreneurs And Investors Living Outside The US by Stephen Flott, Omar Saleh, and Louisa…
DetailsThe article was first published in Global Tax Weekly, issue 167. Below is the full text of the sixth article in the series on US taxes for US persons living outside the US. The US Foreign Account Tax Compliance Act by Stephen Flott, and Flott & Co. This is the sixth article in a series of…
DetailsBy: Joseph Siegmann, and The Internal Revenue Service (IRS) created the Offshore Voluntary Disclosure Program (OVDP) and the Streamlined Domestic Offshore Procedure (SDOP) to encourage taxpayers to disclose foreign accounts and income that were subject to reporting but were not previously reported to the IRS. While both the OVDP and SDOP encourage taxpayers to disclose…
DetailsThe article was first published in Global Tax Weekly, issue 154. Below is the full text of the first article in the series on US taxes for US persons living outside the US. United States Tax Compliance And Planning For US Executives, Entrepreneurs And Investors Living Outside The US – An Overview by Stephen Flott…
DetailsFurther to our June 8th, 2014 email regarding the June 3rd, 2014 announcement by the Commissioner of the Internal Revenue Service that changes to the Offshore Voluntary Disclosure Program (OVDP) and Streamlined Compliance Procedure (SCP) were under development, we are pleased to report that yesterday, the Service published changes to the SCP that substantially improve…
DetailsYou may have seen a post like the one below and concluded that the IRS had eased FATCA enforcement for everyone. That is NOT true. During the American Bar Association Section of Taxation meeting in Washington, DC from May 8th through 10th, senior officials of the IRS explained that the announcement made public on Friday, May…
DetailsOn March 28, 2014, the IRS released the final version of the W-8BEN-E. The W-8BEN-E is an important step in enforcing FATCA, and replaces the W-8BEN for non-US entities receiving payments from US payors. The purpose of the W-8BEN-E for non-US entities to certify their FATCA status. However, it is still the responsibility of the US payor to request the…
DetailsLast Wednesday, the US Treasury and IRS announced that jurisdictions that have reached agreements in substance with the US on the provisions of intergovernmental agreements under the Foreign Account Tax Compliance Act (“FATCA”) will be treated as having agreements in effect until December 31, 2014.
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