On July 30, 2012, the IRS issued their PLR 104521-12 finding that a Fideicomiso was not a trust for federal tax purposes and that for US tax purposes it is actually a tax nothing or and ignored entity. Mexican law provides that only Mexicans can own coastal real estate. In the early 1970s, Mexico's government…
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The United States and Denmark signed FATCA Bilateral Agreement.
The United States and Denmark signed a reciprocal bilateral agreement and memorandum of understanding setting out a government-to-government approach to implementing the Foreign Account Tax Compliance Act on Nov. 15, 2012. This is the second intergovernmental agreement (IGA) signed by the United States. The first was with the United Kingdom in September. The agreement with…
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IRS To Modify Offers in Compromise.
SB/SE Commissioner Faris Fink said, at the Fall Tax Division Meeting of the American Institute for Certified Public Accountants on Nov. 7, that the IRS will focus more on how it conducts its financial analysis in calculating offers in compromise agreements. IRS will now allow for delinquent state and local taxes as a part of…
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Bank Should Brace for ‘FATCA Cliff’ as Deadlines Converge
Financial institutions should brace for a “FATCA cliff” as they prepare to implement the Foreign Account Tax Compliance Act, PricewaterhouseCoopers LLP says in a news alert. Taxpayers need to be prepared as the Internal Revenue Service heightens its scrutiny of reporting and withholding, both in general and as multiple dates for compliance with the Foreign…
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