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1. PFIC reporting rules do not apply to certain marked-to-market stock   WebExclusive

BY Sally P. Schreiber, J.D.
On Wednesday, the IRS announced that it will amend the regulations governing the reporting requirements for U.S. persons who hold stock in passive foreign investment companies (PFICs). The amendments will provide that, if a taxpayer marks to market PFIC stock under Sec. 475 or any Code section other than Sec.

2. Country-by-country reporting by multinationals  

BY Alistair M. Nevius, J.D.
The Organisation for Economic Co-operation and Development (OECD) has recently been advocating for increased tax transparency and for international cooperation to prevent tax avoidance. One element of this international cooperation that the OECD would like to see implemented is country-by-country income and tax reporting by multinational corporations. Country-by-country reporting would be a boon for tax administrators, but it has the potential to be a compliance nightmare for companies.The OECD’s plan would require multinational companies to report both their income and the taxes they pay to the governments of each country in which they operate, thus allowing those

3. New streamlined procedures and changes to the Offshore Voluntary Disclosure Program are announced   WebExclusive

BY Sally P. Schreiber, J.D.
Just in time for the Foreign Account Tax Compliance Act (FATCA), which goes into effect July 1, the IRS announced changes to its streamlined filing compliance procedures and its Offshore Voluntary Disclosure Program (OVDP) designed to make it easier for taxpayers to comply with their obligations to report offshore assets and accounts (IR-2014-73).

4. Final FATCA rules are issued   WebExclusive

BY Sally P. Schreiber, J.D.
On Thursday, the IRS released a large package of regulations needed to implement the Foreign Account Tax Compliance Act (FATCA). FATCA, enacted as part of the Hiring Incentives to Restore Employment Act of 2010, P.L. 111-147, requires U.S. withholding agents to withhold tax on certain payments to foreign financial institutions (FFIs) that do not agree to report certain information to the IRS regarding their U.S.

5. Swiss court stops handover of tax information to U.S.   WebExclusive

BY Alistair M. Nevius, J.D.
A Swiss court has prevented the handover of information on U.S. account holders to the IRS by the Julius Baer Group Ltd., a Swiss bank (A v. Federal Tax Administration, A-5390/2013 (Fed. Admin. Ct. 1/6/14)).The IRS requested information from the bank on its customers who are U.S. citizens based on its conclusion that Julius Baer employees have taken steps to assist U.S.

6. Six more countries sign FATCA agreements with U.S.   WebExclusive

BY Alistair M. Nevius, J.D.
The Treasury Department announced on Thursday that the United States has signed six more bilateral agreements to implement the reporting and withholding provisions of the Foreign Account Tax Compliance Act (FATCA), P.L. 111-147. The agreements with the Netherlands, Malta, Bermuda, Jersey, Guernsey, and the Isle of Man bring the number of signed FATCA intergovernmental agreements to 18.

7. What to do when a client has an undisclosed foreign account  

BY Scott H. Novak, Esq.
CPAs often have clients with an interest in or signature authority over a foreign account. The IRS has emphasized compliance in reporting requirements for U.S. owners of foreign accounts, but many taxpayers may still not know their responsibilities and liabilities. This article outlines these responsibilities and liabilities and describes current enforcement efforts.DISCLOSURE RESPONSIBILITIESA taxpayer who has an interest in or signature authority over certain foreign accounts must inform the government of the existence of the account each year by checking the box in Part III, line 7a, on Schedule B, Interest and Ordinary Dividends, of the taxpayer’s

8. Guidance issued for FFIs with FATCA agreements   WebExclusive

BY Sally P. Schreiber, J.D.
On Tuesday, the IRS issued its latest guidance in preparation for the implementation of the Foreign Account Tax Compliance Act (FATCA) reporting and withholding requirements (Notice 2013-69). The guidance applies to foreign financial institutions (FFIs) entering into an FFI agreement with the IRS under Sec. 1471 or to FFIs or branches of FFIs treated as reporting financial institutions under an applicable Model 2 intergovernmental agreement (IGA).

9. Final regulations attack artificially generated foreign tax credits   WebExclusive

BY Sally P. Schreiber, J.D.
The IRS issued final regulations on determining the amount of taxes paid for purposes of the foreign tax credit (T.D. 9634). The regulations are designed to curb certain transactions that the IRS says “produce inappropriate foreign tax credit results.” They finalize proposed regulations issued in 2011 with no substantive change (REG-126519-11) and remove the temporary regulations issued at the same time (T.D.

10. Online FATCA registration system launched   WebExclusive

BY Alistair M. Nevius, J.D.
The IRS on Monday announced the launch of an online system that foreign financial institutions (FFIs) can use to register with the agency to meet their obligations under the Foreign Account Tax Compliance Act (FATCA) (IR-2013-69 (8/19/13)). The system allows institutions that must register with the IRS to create an account and provide the required information.
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