SBSE-05-0213-009 February 7, 2013 Impacted: IRM 5.21.7 Procedures for Obtaining an ITIN when Requesting ASFR/SFR Reconsideration Current procedures for requesting an ITIN for cases in which ASFR/SFR reconsideration is needed has caused delays and confusion in processing the Form 3870 adjustment. Both the ITIN Operation and the ASFR/SFR unit need the original return to…
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OECD Could Lead to Redefining Global Taxation Rules
The OECD produced this report from the concern of many of it members regarding whether there is fair taxation of the profits of multinational corporations operating in the global market as compared to smaller businesses which operate mainly in domestic market. On February 12, 2013, the OECD released its report Addressing Base Erosion and Profit…
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Asia is a Huge Hurdle for Fatca Agreements!
While the US is pushing to sign up as many countries as possible to an IGA, for Hong Kong & China signing an IGA appears less appealing. Speaking at a PwC Fatca roundtable in Hong Kong on February 6, Anthony Tong, US tax consulting leader for Greater China, said it is the US that would…
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Foreign Trusts With Individual Trustees Are NFFE's & Are Not Subject to FATCA Reporting.
As we reported on Monday, January 28, 2013 in our post Significant Changes in Final FATCA Regulations, the US Treasury Department published final rules governing enforcement of the Foreign Account Tax Compliance Act (FATCA). The regulations indicate that trusts with individual trustees will be NFFEs (non financial foreign entities), whether those individuals are professional trustees are not.…
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