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Switzerland has recently become one of the most active countries with respect to expanding its network of automatic exchange of information agreements (Swiss AEOI Agreements). In fact, since January 1, 2017, nine Swiss AEOI Agreements entered into force. Nine Swiss AEOI Agreements All of the Swiss AEOI Agreements were signed via exchange of notes in […]
On December 23, 2016, Argentina and the United States signed a Tax Informational Exchange Agreement (“Argentinian Tax Information Exchange Agreement” or “Argentinian TIEA”) in Buenos Aires. Let’s explore the main points of the Argentinian Tax Information Exchange Agreement. Argentinian Tax Information Exchange Agreement: Information to Be Exchanged The information to be exchanged under the Argentinian […]
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 […]