In PLR 201242003, the IRS permitted tax deferral under Section 1031 even though the Exchange Accommodation Titleholder entered into Qualified Exchange Accommodation Arrangements with more than one entity, including entities related to the taxpayer, who both had a bona fide intent to utilize a reverse exchange format to defer capital gain taxes. PLR 20122003 notes…
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Russian Banks Soon Subject to U.S. Monitoring.
Russia's presidential executive office has been reviewing the U.S. anti-money laundering act known as FATCA (Foreign Account Tax Compliance Act). Presidential economic advisor Elvira Nabiullina spearheaded a meeting with Finance Ministry, Foreign Ministry, Central Bank, Federal Financial Markets Service, Tax Service and National Payment Council officials, issuing instructions to prepare final proposals within the next…
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Another Whistleblower Award – IRS Pays $38 Million!
The Internal Revenue Service has awarded an anonymous whistleblower $38 million for information leading to the recovery of between $127 million and $254 million in corporate taxes, according to the whistleblower's attorney. The payment is believed to be the second-largest whistleblower award under a program created by Congress that took effect in 2007. The program…
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New Timelines for FATCA
We originally Posted on October 25, 2012 - FATCA Timelines for Due Diligence & Other Requirements - Ann 2012-42, which discusses IRS Announcement 2012-42. The announcement presents new timelines for due diligence, withholding and documentation requirements as well as guidance on gross proceeds and grandfathered obligations. The following are the key timeline changes announced and…
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