August 1, 2012
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BY
Megan Marlin, J.D., LL.M. and Kevin Curran, J.D., LL.M.
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Article
Taxpayers traveling to the United States with unpaid U.S. tax assessments can be detained at the border, questioned, and flagged for follow-up enforcement. If a taxpayer has an unpaid tax liability and is subject to a resulting Notice of Federal Tax Lien, the IRS may submit identifying taxpayer information to the Treasury Enforcement Communications System (TECS), a database maintained by the Department of Homeland Security (DHS).
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August 1, 2012
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BY
Megan Marlin, J.D., LL.M. and Kevin Curran, J.D., LL.M.
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Article
Taxpayers traveling to the United States with unpaid U.S. tax assessments can be detained at the border, questioned, and flagged for follow-up enforcement. If a taxpayer has an unpaid tax liability and is subject to a resulting Notice of Federal Tax Lien, the IRS may submit identifying taxpayer information to the Treasury Enforcement Communications System (TECS), a database maintained by the Department of Homeland Security (DHS).
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August 1, 2012
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BY
Megan Marlin, J.D., LL.M. and Kevin Curran, J.D., LL.M.
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Article
Taxpayers traveling to the United States with unpaid U.S. tax assessments can be detained at the border, questioned, and flagged for follow-up enforcement. If a taxpayer has an unpaid tax liability and is subject to a resulting Notice of Federal Tax Lien, the IRS may submit identifying taxpayer information to the Treasury Enforcement Communications System (TECS), a database maintained by the Department of Homeland Security (DHS).
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May 1, 2012
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Article
The IRS issued final regulations on determining who has the legal liability to pay the foreign tax for foreign tax credit (FTC) purposes (T.D. 9576) and temporary regulations on the application of the “anti-splitter” rules of Sec. 909 (T.D. 9577). The rules are related because the legal liability to pay foreign tax affects the determination of whether foreign income has been inappropriately split off from the tax under Sec.
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May 1, 2012
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Article
The IRS issued final regulations on determining who has the legal liability to pay the foreign tax for foreign tax credit (FTC) purposes (T.D. 9576) and temporary regulations on the application of the “anti-splitter” rules of Sec. 909 (T.D. 9577). The rules are related because the legal liability to pay foreign tax affects the determination of whether foreign income has been inappropriately split off from the tax under Sec.
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May 1, 2012
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Article
The IRS issued final regulations on determining who has the legal liability to pay the foreign tax for foreign tax credit (FTC) purposes (T.D. 9576) and temporary regulations on the application of the “anti-splitter” rules of Sec. 909 (T.D. 9577). The rules are related because the legal liability to pay foreign tax affects the determination of whether foreign income has been inappropriately split off from the tax under Sec.
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April 18, 2012
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BY
Sally P. Schreiber
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Article
The IRS issued final regulations under Sec. 6049 outlining the rules requiring U.S. financial institutions to report interest payments to certain nonresident alien individuals of $10 or more per year paid after Dec. 31, 2012 (T.D. 9584). The IRS explained that the new rules are part of the process of improving the detection of tax evasion worldwide.
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March 13, 2012
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Article
TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), must be filed by U.S. persons having a financial interest in or signature authority or other authority over any financial account in a foreign country if the aggregate value of these accounts exceeds $10,000 at any time during the calendar year.
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February 27, 2012
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BY
Alistair M. Nevius
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Article
The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced that it is postponing until July 1, 2013, its requirement that Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), be filed electronically. FinCEN notes that the delay in the e-filing requirement does not relieve anyone of the obligation to file a paper FBAR or postpone the paper-filing due date.
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February 15, 2012
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BY
Sally P. Schreiber
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Article
The Financial Crimes Enforcement Network (FinCEN) announced a further extension of the deadline for filing Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), to June 30, 2013, for a small group of financial professionals (FinCEN Notice 2012-1). In 2011, FinCEN announced that three small groups of individuals would receive a one-year FBAR extension beyond the June 30, 2011, filing deadline (FinCEN Notice 2011-1; FinCEN Notice 2011-2) to June 30, 2012.
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