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The Internal Revenue Service Criminal Investigation Division (IRS-CI) and Her Majesty’s Revenue & Customs (HMRC) co-hosted a three-day International Criminal Tax Symposium in Washington, D.C. on January 27 – 29, 2015. The symposium focused on combating offshore tax evasion and international financial crimes. It is worth mentioning that delegates from criminal tax and enforcement programs […]
In a previous article, I discussed the eligibility requirement with respect to the Streamlined Domestic Offshore Procedures. In this article, I would like to explore the specific filing requirements under the Streamlined Domestic Offshore Procedures. As a side note, it is important to emphasize that this is just an educational article on the general overview […]
The Title 26 Miscellaneous Offshore Penalty (“Miscellaneous Offshore Penalty”) is one of the most critical aspects of the Streamlined Domestic Offshore Procedures (“SDOP”). In this article, I want to conduct a general overview of how the Miscellaneous Offshore Penalty is calculated. As a side note, it is important to keep in mind that this is an […]
One of the most important tax aspects involving trusts in cross-border tax situations is the determination of the residency of a trust- i.e. whether it is a domestic or foreign trust for US tax purposes. This determination of the residency of a trust will have important tax consequences for US taxpayers. In this article we […]
On January 12, 2015, the IRS announced the opening of the International Data Exchange Service (IDES) for enrollment. The appearance of IDES is not a surprise to FATCA Attorneys, because most FATCA attorneys knew IDES was the next logical step since its purpose is going to be for foreign financial institutions (FFIs) and host country […]