FTS is an optional strategy to reach resolution when the SB/SE examiner and manager and the taxpayer have exhausted established issue resolution strategies. For eligible cases, FTS allows taxpayers that have unagreed issues to work with SB/SE Examination and the Office of Appeals (Appeals) to resolve the issues while the case remains in SB/SE's jurisdiction.…
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US Boycott Leaves Russia No Time to Comply With FATCA
The US government has broken off FATCA treaty negotiations with Russia because of the Ukraine crisis. As the United States attempts to punish Russia for its actions in Ukraine, the Treasury Department is deploying an economic weapon that could prove more costly than sanctions: the Internal Revenue Service.Beginning in July, U.S. banks will be required to…
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IRS Announces That Tax Rules for Overseas Banks Will See Light Enforcement In the Next 2 Years!
IRS Notice 2014-33 announces that calendar years 2014 and 2015 will be regarded as a transition period for purposes of IRS enforcement and administration with respect to the implementation of FATCA by withholding agents, foreign financial institutions (FFIs), and other entities with chapter 4 responsibilities, and with respect to certain related due diligence and withholding…
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IRS Provides New FATCA Guidance for Branches & Disregarded Entities
The Internal Revenue Service has provide new guidance in Issue Number:2014-11 on how branches and disregarded entities need to register for the Foreign Account Tax Compliance Act, with changes that come as a surprise for many foreign financial institutions. ALERT #4 indicates that New FATCA Frequently Asked Questions (FAQs) and Answers have been posted to…
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