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Outbound business tax planning should form part of every outbound business transaction, whether it is in technology transfers, export of goods or an investment overseas. In this article, I would like to discuss the main goal of the outbound business tax planning and identify the overall “global” (i.e. looking at the entire genre of outbound […]
Using proper currency conversion rates is a critical part of preparing 2016 FBAR and 2016 Form 8938. The instructions to both forms require (in case of Form 8938, this is the default choice) US taxpayers to use the 2016 FBAR Currency Conversion Rates published by the Treasury Department. The 2016 FBAR Currency Conversion Rates also […]
Switzerland has recently become one of the most active countries with respect to expanding its network of automatic exchange of information agreements (Swiss AEOI Agreements). In fact, since January 1, 2017, nine Swiss AEOI Agreements entered into force. Nine Swiss AEOI Agreements All of the Swiss AEOI Agreements were signed via exchange of notes in […]
On December 23, 2016, Argentina and the United States signed a Tax Informational Exchange Agreement (“Argentinian Tax Information Exchange Agreement” or “Argentinian TIEA”) in Buenos Aires. Let’s explore the main points of the Argentinian Tax Information Exchange Agreement. Argentinian Tax Information Exchange Agreement: Information to Be Exchanged The information to be exchanged under the Argentinian […]
International tax lawyers should focus not only on substantive, but also on procedural defenses against the results of an FBAR audit. One such potential defense against FBAR audit is a related-statute IRC §6103(h) violation. Related-Statute IRC §6103(h) Violation: Background Information In a previous article, I already discussed the fact that IRC §6103(a) limits somewhat the […]