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Significant Changes in Final FATCA Regulations

 As we have reported on January 17th,  in our post IRS Issue Final Regulations to Combat Offshore Tax Evasion, the US Treasury Department published final rules governing enforcement of the Foreign Account Tax Compliance Act (FATCA). The Final Regulations make a number of changes to the extensive proposed regulations released last February, in particular: All debt…
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CCM 201250020 – Use of Third-Party Return Information In Captive Insurance Audits

The Office of Chief Counsel, Internal Revenue Service, issued Chief Counsel Memorandum 201250020 on  Dec. 14, 2012 stating that: "The Service may disclose the third party return information in the exams of the unrelated taxpayers to the extent the documents satisfy the “item test” of section 6103(h)(4)(B)." The documents satisfy the “item test” if they directly relate to…
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2013 Mexican Tax Amnesty

As of 1 January 2013, Mexico is granting a tax amnesty for federal taxes, certain fees and penalties levied on the failure to fulfill tax obligations (different from payment obligations). The main requirement for the application of the tax amnesty is to pay the remaining portion of the unpaid tax, fee or penalty in one…
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IRS Issue Final Regulations to Combat Offshore Tax Evasion

Page Content The U.S. Department of the Treasury and the Internal Revenue Service (IRS) today issued comprehensive final regulations implementing the information reporting and withholding tax provisions commonly known as the Foreign Account Tax Compliance Act (FATCA). Enacted by Congress in 2010, these provisions target non-compliance by U.S. taxpayers using foreign accounts. The issuance of…
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