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On March 30, 2015, the US Department of Justice announced that BSI SA, one of the 10 largest private banks in Switzerland, was the first bank to reach a resolution under the DOJ Swiss Bank Program. Background Information The Swiss Bank Program, which was announced on August 29, 2013, provides a path for Swiss banks […]
As a Minneapolis MN FATCA Tax Lawyer, I often receive questions about what US tax forms precisely are affected by the implementation of the Foreign Account Tax Compliance Act (FATCA). Here is a list of the tax forms most affected by FATCA: 1. Minneapolis MN FATCA Tax Lawyer: IRS Form 1042 and 1042-S Form 1042 […]
On March 20, 2015, the Cayman Islands FATCA Registration Portal was launched by the Department for International Tax Cooperation (which is a department within Cayman Islands Tax Information Authority). Cayman Islands FATCA Background The Cayman Islands FATCA Registration Portal is part of the long process of Cayman Islands FATCA compliance. Cayman Islands FATCA IGA (Model […]
On March 13, 2015, the IRS announced that the underpayment and overpayment interest rates for the calendar quarter beginning April 1, 2015, will remain unchanged. The rates will be: three (3) percent for overpayments [two (2) percent in the case of a corporation];three (3) percent for underpayments;five (5) percent for large corporate underpayments; andone-half (0.5) […]
Various Form 5471 penalties are associated with failure to file Form 5471 or the filing of an incorrect Form 5471. In this article, I will describe the most important of these penalties. IRS Form 5471 The IRS Form 5471 is an extremely complex form that is used to satisfy the reporting requirements of two esoteric […]