Amid much fanfare, a new Swiss law entered into force on August 1, 2014 making it easier for other countries to extract information on tax dodgers. The revised Tax Administrative Assistance Act (TAAA) now permits Swiss banks to respond to a wider range of administrative assistance requests concerning their foreign clients. Anyone hoping that Switzerland’s…
Read more
EU Parent Subsidiary Directive Amended So Hybrid Entities Will No Longer Qualify!
The Council on July 8, 2014 formally adopted an amendment to EU tax rules that will prevent the double non-taxation of dividends distributed within corporate groups deriving from hybrid loan arrangements. This follows political agreement at the Council's meeting on June 20, 2014 . "The adoption of this amendment to the parent-subsidiary directive is an important step change…
Read more
How Do I Determine My Liability For FBAR Penalties Under the Penalty Mitigation Guidelines?
Original Post By Michael DeBlis. The IRS has authority to assert FBAR civil penalties. Contrary to popular belief, an FBAR violation doesn’t automatically mean that a penalty will be asserted. Examiners are expected to exercise discretion, taking into account the facts and circumstances of each case, in determining whether penalties should be asserted. For example,…
Read more
