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1. Changes made to IRS streamlined offshore compliance procedures   WebExclusive

BY Sally P. Schreiber, J.D.
The IRS updated its streamlined offshore compliance program to provide procedures taxpayers residing both inside and outside the United States should use to participate in the program. The streamlined offshore compliance program is for taxpayers whose failure to comply with requirements to report offshore assets is nonwillful. It is designed to allow U.S.

2. Certain FATCA deadlines are postponed   WebExclusive

BY Sally P. Schreiber, J.D.
The IRS announced its intention in Notice 2014-59 to amend temporary regulations it issued under the Foreign Account Tax Compliance Act (FATCA) on March 6, 2014, to modify the effective dates of (1) the standards of knowledge that apply to a withholding certificate or documentary evidence to document a payee that is an entity under Regs.

3. The tip of the iceberg: Professional liability claims and international taxation  

BY Deborah K. Rood
International tax issues can present significant challenges for a CPA firm. Even the smallest client may provide goods or services outside the United States or use a foreign supplier, sometimes without the CPA even realizing it. For example, such situations may include owning or having signatory authority on foreign bank accounts, owning a foreign entity, being a beneficiary of a foreign trust, or paying a foreign service provider for work performed in the United States.

4. 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.

5. 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

6. 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

7. Supreme Court resolves circuit split on creditability of U.K. tax  

In a unanimous decision, the U.S. Supreme Court held that the United Kingdom’s windfall profits tax imposed on newly privatized businesses was creditable against U.S. taxes under Sec. 901 (PPL Corp., No.12-43 (U.S. 5/20/13)). In doing so, the Court reversed the Third Circuit’s decision (665 F.3d 60 (3d Cir.

8. GAO: Foreign account “quiet disclosures” may be much higher than detected  

More than 10,000 taxpayers showed signs of having avoided offshore penalties by making “quiet disclosures” of foreign bank accounts for tax years 2003 through 2008, the U.S. Government Accountability Office (GAO) reported, a period for which the IRS has detected several hundred quiet disclosures. Filing data also suggest many more taxpayers may have begun reporting previously reportable foreign accounts on a recent current-year return without entering the government’s offshore voluntary disclosure program (OVDP) or making a quiet disclosure for prior open years, the GAO said.

9. FATCA final regulations cover all the bases  

The IRS issued final regulations providing rules on information reporting by foreign financial institutions (FFIs) and withholding on certain payments to FFIs and other foreign entities (T.D. 9610). Under the Foreign Account Tax Compliance Act of 2009 (FATCA), enacted as part of the Hiring Incentives to Restore Employment Act of 2010, P.L.

10. The basic framework of cross-border taxation  

BY Alistair M. Nevius
U.S. citizens are taxable on their worldwide income, with a credit or deduction for taxes paid on foreign income. The United States makes no distinction between earnings from business or investment activities within the United States and those outside its borders. Tax laws governing cross-border transactions are both arcane and complex, and they present a host of traps, demanding familiarity with the basic tax rules that apply to both U.S.
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