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This is a natural question for an OVDP International Tax Attorney: in light of the ongoing U.S. Department of Justice (“DOJ”) The Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (the “Program”), should every U.S. taxpayer with undisclosed Swiss accounts enter the Program? As everything in international tax law, the answer of whether […]
As many OVDP Foreign Accounts Lawyers know, April 30, 2014 is a crucial deadline for the U.S. Department of Justice (“DOJ”) The Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (the “Program”). By this date, numerous Swiss banks will have to disclose the names of US accountholders, account balance information, and various other […]
Minnesota tax attorneys and attorneys in other states warn their clients that there are two important IRS deadlines next Monday, March 17, 2014. First, corporate income tax returns are due for corporations with fiscal year ending on December 31, 2013. Normally, the deadline would be on March 15, but because this date falls on Saturday, […]
On February 5, 2014, the U.S. Department of the Treasury announced that the United States signed an intergovernmental agreement (IGA) with Canada to implement the Foreign Account Tax Compliance Act (FATCA). Since Treasury last announced multiple IGA signings in mid-December 2013, agreements have also been signed with Italy and Mauritius, the latter of which also […]
As an OVDP International Tax Lawyer, I continue to point out the centrality of the current U.S. Department of Justice (“DOJ”) The Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (the “Program”) to the global international tax compliance efforts of the United States. As previous explained, the Program basically operates as a voluntary […]