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Monthly Archives: December 2016

Argentina Signs Information-Sharing Agreement With the U.S.

The agreement, which Argentine officials said they were pursuing in September, is part of a government crackdown on alleged tax evasion by individuals. Argentina also has implemented a tax amnesty plan to recover an estimated $500 million in assets held abroad.In a December 23, 2016 statement, Treasury Secretary Jacob J. Lew said the U.S. hopes…
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1st Circ. Ct of Appeals Reverses Santander's $234M Foreign Tax Refund

According to Law360  the First Circuit Court of Appeals overturned an earlier $234 million victory for Santander Holdings USA Inc. after ruling on December 16, 2016 that an internal securities transaction the bank had engaged in lacked economic substance and does not qualify for foreign tax credits.   On November 16, 2015 we posted Judge Rules Thant IRS…
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