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Yearly Archives: 2014

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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