International Tax News

Foreign Tax-Free Savings Accounts Obligations

IRS Explains Intermediaries’ Obligations on Foreign Tax-Free Savings Accounts The IRS has revised its frequently asked questions (FAQs) on Qualified Intermediaries (QIs), Withholding Foreign Partnerships (WPs), and Withholding Foreign Trusts (WTs), in relation to the Foreign Account Tax Compliance Act (FATCA). The changes are aimed at providing guidance on a QI’s obligations under the 2017…

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FBAR Willful Failure Reg Ruled Invalid

Federal Claims Court Rules FBAR Willful Failure Reg Is Invalid Coming to the opposite conclusion reached by two district courts, the U.S. Court of Federal Claims has held that a reg is invalid if it doesn’t reflect a statutory increase in the penalty for willfully failing to file a Report of Foreign Bank and Financial…

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IRS Falters on FATCA Compliance

Despite Huge Spending, IRS Falters on FATCA Compliance Efforts The Treasury Inspector General for Tax Administration (TIGTA) has determined that, despite spending nearly $380 million, the IRS still isn’t prepared to enforce the Foreign Account Tax Compliance Act (FATCA). TIGTA determined that the IRS has taken limited or no action on most of the planned activities…

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IRS Closes Corporate Inversion Loopholes

IRS Finalizes Regs that Close Loopholes for Corporate Inversions The IRS has issued final regs aimed at curbing inversion tactics that corporations use to avoid U.S. income taxes. Basically, corporate inversions (also called “expatriation transactions”) generally involve a U.S. corporation engaging in a series of transactions with the effect of moving its headquarters from the U.S….

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IRS Clarifies FBAR “Willfulness”

IRS Clarifies ‘Willfulness’ Under FBAR Rules The IRS has set out the definition of “willfulness,” and the standard of proof for establishing violations under the rules for submitting a Report of Foreign Bank and Financial Accounts (FBAR). In a Program Manager Technical Advice, the IRS has concluded that the standard for willfulness is the civil, rather…

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