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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 […]
On January 18, 2017, three US taxpayers pleaded guilty for hiding millions of dollars in their secret Swiss and Israeli bank accounts (hereinafter “Swiss-Israeli Bank Accounts”) and failing to report these Swiss-Israeli Bank Accounts on their FBARs. Facts of the Case Involving Secret Swiss-Israeli Bank Accounts All three defendants are relatives – Mr. Dan Farhad […]
On January 17, 2017, US-Slovenia Totalization Agreement was signed in Slovenia. Ms. Anja Kopac Mrak, the Slovenian minister of labor, family, social affairs, and equal opportunities, signed on behalf of Slovenia. Mr. Brent Hartley, US Ambassador to Slovenia, signed on behalf of the United States. Signing of the US-Slovenia Totalization Agreement represents a major step […]
On January 18, 2017, the HM Revenue & Customs announced that the withholding tax on royalties under the 1994 Estonia-UK tax treaty has been eliminated retroactively as of October 16, 2015. Under the original Estonia-UK tax treaty, the rates had been 5 percent for industrial, commercial, and scientific equipment royalties and 10 percent in other […]
On January 16, 2017, the Belarus-Hong Kong Tax Treaty was signed by government officials from both countries – K.C. Chan, Hong Kong’s secretary for financial services and the treasury, and Sergei Nalivaiko, Belarusian minister of taxes and duties. Let’s explore the most important provisions of the new Belarus-Hong Kong Tax Treaty. Elimination of Double-Taxation Under […]