Fatca and the model agreement signed with the EU’s largest economies have not been without critics, notably from the international group, Geneva-based American Citizens Abroad, and Canada, which has a large US citizen population (background from Canada’s Bankers Association). Switzerland and the United States 21 June published a joint declaration containing key points for possible…
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IRS Releases Draft of Forms W-8EXP and W-8ECI
The IRS releases a draft Form W-8EXP. Little of substance is changed on the form, but it incorporates the "checkbox" approach to capacity first seen on the draft Form W-8ECI. The IRS releases a draft revised Form W-8ECI. The Internal Revenue Service has eliminated a troublesome requirement that people authorized to sign some forms related…
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Fifth Amendment Does Not Apply to Offshore Banking Records
The Fifth Amendment privilege against self-incrimination does not apply to records that fall under the Required Records Doctrine, and a taxpayer who is the subject of a grand jury investigation into his use of offshore bank accounts cannot invoke the privilege to resist compliance with a subpoena seeking records kept pursuant to the Bank Secrecy…
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IRS Rules – May adopt a CAP Decision as part of a CDP Hearing
The IRS Office of Chief Counsel said in a program manager technical advice memorandumPMTA2012-14, that a settlement officer may adopt the CAP decision as part of the determination in the CDP hearing but is not required to do so. 1) Section 6330(c)(4) does not preclude consideration during a CDP hearing of an issue that…
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