The Financial Times (FT) ran a story on Saturday 18 October about confusion over the Foreign Account tax Compliance Act (FATCA) deadline for trusts. Trustees of private family trusts are being urged to register with the US tax authority or risk non-compliance with new counter-tax avoidance legislation. Investment-based trusts that are managed by a discretionary…
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Definition of Willfulness in OVDP Streamline Program Intentionally Left Vague!
According to the IRS website, Streamlined Filing Compliance Procedures, the streamlined procedures are available to taxpayers certifying that their failure to report foreign financial assets and pay all tax due in respect of those assets did not result from willful conduct on their part.We previously posted on Wednesday, October 1, 2014, So What Does "Non-Willful" Really…
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The Swiss government released Q&A's on Automatic Exchange of Information
Friday, October 10, 2014, we posted Swiss Consider Automatic Exchange of Information Pursuant to Model 1 FATCA Agreement! where we discussed that the mandates definitively adopted by the Federal Council are: The introduction of the automatic exchange of information is to be negotiated with the EU. Regarding implementation of the Foreign Account Tax Compliance Act (FATCA),…
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Deutsche Bank is the Latest Swiss Bank which is Turning Over Names of its US Depositors!
The Swiss subsidiary of Deutsche Bank is cooperating with the IRS and Justice Department to disclose accounts belonging to or affiliated with Americans. U.S. law requires taxpayers holding more than $10,000 in offshore financial assets (such as bank accounts) to report those accounts or face huge penalties. Reporting must be done annually and is done…
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