Are you still wondering how the IRS will perceive your clients OVDP filing, with your associated requests for lower penalties or with some other legal tax position regarding your client, which is based upon relevant legal precedent? Well wonder no longer, as one of our colleagues, the Brager Tax Law Group, requested the IRS's documents…
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FATCA Update! – 101 FATCA Agreement To Date!
The IRS released Announcement 2014-38 which provides guidance with respect to jurisdictions that are treated as if they had a FATCA intergovernmental agreement (IGA) in effect pursuant to Announcement 2014-17, 2014-18 I.R.B. 1001, but that do not sign the IGA before December 31, 2014. Announcement 2014-38 provides that a jurisdiction that is treated as if…
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Confirmation that Barclays' Private Bank in Switzerland has dropped out of a U.S. Program
We had posted on September 9, 2014 10 Swiss Banks Withdraw From US DOJ's Program where we discussed that According to Swiss newspaper NZZ am Sonntag, quoting unnamed sources, 10 Swiss Banks that requested the US Department of Justice's non-prosecution program have now withdrawn from it because they have decided they did not systematically break US tax laws (Lets…
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