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
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TOPICS / TAX
International tax
The tip of the iceberg: Professional liability claims and international taxation
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.
PFIC reporting rules do not apply to certain marked-to-market stock
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.
Country-by-country reporting by multinationals
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
New streamlined procedures and changes to the Offshore Voluntary Disclosure Program are announced
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
Accounting across borders
CPA firms are finding international services a booming business, based on responses to a recent AICPA Private Companies Practice Section (PCPS) survey. The survey examines practitioners’ interest in expanding to new markets and growing an international clientele, as well as firms’ top international challenges and needs.
Final FATCA rules are issued
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
Swiss court stops handover of tax information to U.S.
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
Six more countries sign FATCA agreements with U.S.
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
What to do when a client has an undisclosed foreign account
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
Guidance issued for FFIs with FATCA agreements
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
Final regulations attack artificially generated foreign tax credits
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
Online FATCA registration system launched
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
IRS issues draft FATCA report form
On Thursday, the IRS released a draft Form 8966, FATCA Report, which will be used by foreign financial institutions (FFIs) and withholding agents to comply with their FATCA reporting and withholding requirements. Under the Foreign Account Tax Compliance Act (FATCA), enacted as part of the Hiring Incentives to Restore Employment
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. 2011))
FATCA deadlines are postponed for six months
On Friday, the IRS said it was delaying for six months some of the deadlines for implementing the Foreign Account Tax Compliance Act (FATCA) originally set out in the final regulations issued in April in T.D. 9610 (Notice 2013-43). The regulations, which provide rules on information reporting by foreign financial
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
Indoor tanning tax final regulations issued
On Monday, the IRS issued final regulations on the 10% excise tax that has been in effect for amounts paid for indoor tanning services since July 1, 2010 (T.D. 9621). The regulations, which apply to amounts paid on or after June 11, 2013, finalize proposed rules issued in 2010 when
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. 2011))
IRS sends letters to taxpayers as it tries to close out inventory of Form 3520 processing issues
The IRS has recently notified the AICPA’s Foreign Trust Task Force that the IRS plans over the next few months to send out letters to taxpayers who filed Form 3520, Annual Return to Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts, or Form 3520-A, Annual Information Return
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