International tax

FBAR compliance

Heightened tax compliance efforts worldwide make this a good time to review the complicated rules that apply to reporting foreign accounts on FinCEN Form 114, Report of Foreign Bank and Financial Accounts, commonly known as FBAR.

Overview of the ECI rules

This sidebar provides a brief explanation of the Internal Revenue Code’s effectively connected income (ECI) rules that may impose direct U.S. tax on certain income earned by any foreign corporation.

Proposed regulations outline country-by-country reporting requirements

The much-anticipated rules, under which the US would adopt the Organisation for Economic Co-operation and Development’s country-by-country reporting regime, would require reporting by multinational enterprise groups with revenue of $850 million or more in the prior annual accounting period.

FBAR penalty amount guidelines set

Maximum penalties for willful failure to report foreign bank accounts on FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR), for multiple years are limited under new IRS procedures.

Tax phishing goes global with FATCA

Scam artists impersonating the IRS have been requesting foreign financial account holders’ personal and account information, the IRS warned in a news release.

IRS puts would-be corporate inverters on notice

Coming regulations will reduce tax benefits of inversions by preventing certain uses of controlled foreign corporations and closing loopholes in the Sec. 7874 anti-inversion provisions.

Certain FATCA deadlines are postponed

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

Changes made to IRS streamlined offshore compliance procedures

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

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