March has started well in the Treasury Department’s ongoing efforts to implement FATCA. The Treasury Department inked two more FATCA intergovernmental agreements (IGA’s) on March 5, 2014. Importantly, Chile has signed an IGA, the first country in South America. The Finnish IGA agreement is based on the Model 1A treaty and requires Finnish financial institutions…
DetailsOn March 10th, 2014, we had an opportunity to hold a follow up telephone discussion with the IRS about the Steamlined Filing Compliance Procedures for Non-Resident, Non-Filer US Taxpayers (SCP) introduced in June 2012. Readers of this blog will recall that we voiced several concerns about the SCP in a letter addressed to David Horton…
DetailsUS International Tax Counsel, Danielle Rolfes, confirmed on 28 February 2014 during remarks to the Federal Bar Association Section of Taxation meeting in Washington that the 1 July 2014 effective date for implementation of the Foreign Account Tax Compliance Act (FATCA) will not be extended. She also said that FATCA is not going to be…
DetailsOn January 10, 2014, the US and Italy entered into a bilateral agreement for the implementation of FATCA The Italian agreement is based on the Model 1A treaty and requires Italian financial institutions to report their US account holders to the Italian government, which in turn will report those accounts to the US government. Similarly,…
DetailsDecember was a fruitful month for the US Treasury Department’s efforts to implement FATCA. The Treasury Department inked another six FATCA bilateral agreements which increases the total number of bilateral agreements to 18. The Malta, Netherlands, Guernsey, Isle of Man, Jersey agreements are based on the Model 1A treaty and requires the foreign financial institutions…
DetailsUS TAX SURPRISES AND REPORTING REQUIREMENTS SERIES Here we will briefly discuss the ownership attribution rules for purposes of Form 5471, and introduce the different filing categories under Form 5471. The rules and reporting requirements for each category of filer are unique and will be discussed in more detail in subsequent articles. Before describing the…
DetailsSeminar on The US Taxation Of International Shipping offered by Stephen Flott, Esq. on November 7th and 8th, 2013 to the Dexter House in London.
US TAX SURPRISES AND REPORTING REQUIREMENTS SERIES If you are a US person (citizen or resident) you may have learned by now that you have to file a US tax return and bank report each year, even if you have no US source income. Well, that’s not all. This is the first in a series…
DetailsOn November, 14 2013, the US and France signed a bilateral agreement to implement the Foreign Account Tax Compliance Act (FATCA). The agreement is based on the Model 1A treaty and requires French financial institutions to report US account holders to the French government, which will then report those accounts to the US. Similarly, US financial institutions are required…
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