On July 27, 2018 we posted 2nd Taxpayer Victory on a FBAR Penalty Case - FBAR Limited to $100M! where we discussed US v. Dominique G. Colliot, case number 1:16-cv-01281, in the U.S. where a District Court for the Western District of Texas how that the maximum FBAR penalty was limited to $100,000 a year. We also discussed…
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IRS & Treasury Issue Proposed Regulations Implementing IRC Section 965 Transition Tax
The Internal Revenue Service and the Department of the Treasury on August 1, 2018 issued proposed regulations on Section 965 of the Internal Revenue Code. The proposed regulations affect United States shareholders, as defined under section 951(b) of the Code, with direct or indirect ownership in certain specified foreign corporations, as defined under section 965(e)…
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US Removes Beneficial Ownership Registration From Bill HR 6068
The U.S. House of Representatives Committee on Financial Services scheduled a June 14th markup on the Counter Terrorism and Illicit Finance Act (HR 6068) (CTIFA), which has been stripped of provisions that would require collection of beneficial ownership information at the time of company formation, a necessary step to address this widely-recognized and well-documented vulnerability in…
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Have an Offshore Account with Mirelis InvestTrust? You May Want to Consider the OVDP Program Before Sept. 28!
The DoJ announced on Friday, July 27, 2018today that Swiss-based Mirelis Holding S.A. reached a resolution with the Tax Division. “The agreement reached today demonstrates the Department’s resolve toward ending the practice of using Swiss bank accounts to evade one’s taxes,” said Principal Deputy Assistant Attorney General Richard E. Zuckerman DoJ Tax Division. “The Department will…
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