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Yearly Archives: 2012

Swiss banking secrecy laws have been further eased, with parliament passing a law on tax cooperation and backing – in principle – a special deal with the United States.

In a lengthy and at times passionate debate which included discussion of some two dozen proposed amendments, the House of Representatives voted 113 to 58 on Wednesday to pass the government’s proposed law on administrative assistance in taxation matters. The new law replaces a previous regulation for assistance on tax matters and is based on…
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FinCEN Seeks Comments on Strengthening and Clarifying Customer Due Diligence Requirements

VIENNA, Va. – The Financial Crimes Enforcement Network (FinCEN) today issued an advance notice of proposed rulemaking (ANPRM) to solicit public comment on a wide range of questions pertaining to the possible application of an explicit customer due diligence (CDD) obligation on financial institutions, including a requirement for financial institutions to identify beneficial ownership of…
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Estate Responsible for Penalties For Decedent's Failure to Report Foreign Trust

The Internal Revenue Service Office of Chief Counsel, in a chief counsel advice memorandum released Feb. 24, said an estate is responsible for Section 6677 penalties for failure to file information returns regarding foreign trusts for tax years ending prior to the decedent's death. The estate is responsible for “initial” penalties asserted against the decedent…
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FATCA Clears Way for Mexican Authorities to Investigate U.S. Accounts

The Mexican Tax Administration Service (SAT) can access information on thousands of U.S. bank accounts held by Mexican citizens “automatically” under a new collaboration with the IRS. The agreement is part of a reciprocity mechanism between the U.S. and Mexican tax systems stemming from the Foreign Account Tax Compliance Act (FATCA), through which IRS can…
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