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Almost two years ago, the IRS Large Business and International Division announced long-term changes in its structure as well as its approach to tax enforcement. In the fall of 2015, the IRS completed the first phase of the structural changes in the Division – re-organization of its administrative structure. This structure exists intact today and […]
Many persons have assumed that FATCA is a one-way street where only the United States is able to obtain tax information with respect to foreign accounts controlled by its citizens while the information about US bank accounts is never exchanged with other FATCA signatories. While, to some (or even to a large) degree this may […]
On February 28, 2017, the Ministry of Finance of Greece published a list of noncooperative states. What are Noncooperative States In order for a state to be designated as “noncooperative”, it has to satisfy the following four conditions: 1. The state is not a member of the European Union; 2. The state’s legal structure with […]
On February 2, 2017, Mr. Eugene Sherayzen, the founder and owner of Sherayzen Law Office (an international tax law firm headquartered in Minneapolis, Minnesota) gave a lecture at the Italian Cultural Center in downtown Minneapolis. The topic of the lecture was an introduction to US tax reporting of Italian assets and income for individual taxpayers. […]
On January 25, 2017, the federal court in Montana authorized the IRS to serve John Doe Summons on Michael Berg of Bozeman, Montana, seeking information about US taxpayers with offshore accounts established by Sovereign Management & Legal LTD (“Sovereign”), a Panamanian company. In particular, the IRS is interested in US taxpayers who use debit cards […]