The Treasury Department has reached an agreement with the governments of France, Germany, Italy, Spain, and the United Kingdom for designing a framework to implement the information reporting and withholding provisions by foreign financial institutions under the Foreign Account Tax Compliance Act (FATCA). According to Treasury's news release, the governments expressed their “mutual intent to…
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“RELIANCE” DEFENSE WAIVES WORK PRODUCT & ATTORNEY-CLIENT PRIVILEGE PROTECTION
In litigation, the work-product doctrine and the attorney-client privilege protect materials and communications from discovery by an adversary in litigation. The work-product doctrine excludes from discovery materials prepared in anticipation of litigation because discovery of such materials would hamper the orderly prosecution and defense of legal claims in adversary proceedings. The attorney-client privilege extends to…
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How will the IRS find out? Perhaps Whistlebolower?
Internal Revenue Service Whistleblower Office Director Stephen Whitlock told practitioners that the number of claims on which IRS is paying awards has grown dramatically in his five years in the office, and is likely to keep on growing. The IRS Whistleblower Office has received 3,500 submissions since the beginning of fiscal year 2011, with approximately 115 awards…
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Denmark Urges Agreement on EU Savings Tax Changes to Get FATCA Deal With U.S.
EUROPOLITICS BRUSSELS—Denmark urged European Union member states to promptly resolve differences over proposals to revise the EU Savings Tax directive as a way to bridge differences with the U.S. Treasury Department over compliance with the Foreign Account Tax Compliance Act (FATCA). As the current holder of the EU presidency, Denmark stated at a special meeting of…
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