BNA - Over the past three years, the U.S. government has intensified its pursuit of taxpayers who fail to pay taxes on money held in foreign bank accounts; this includes a massive increase in criminal investigations and prosecutions. While “willfulness” is generally recognized to be a high legal standard requiring proof that the accused acted…
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IRS On Track to Issue Proposed Rules, Draft Bank Agreement Under FATCA
Internal Revenue Service is “on track” to issue proposed regulations on the Foreign Account Tax Compliance Act (FATCA) around the end of the year, a top IRS international official said Nov. 17. IRS Large Business & International Division Deputy Commissioner (International) Michael Danilack said if the guidance does not come out by Dec. 31, he…
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Switzerland Eases Rules on Account Data Transfer for U.S. Clients of Swiss Banks
The government of Switzerland has agreed to ease existing rules on the transfer of information on secret Swiss bank accounts of U.S. clients in a further effort to diffuse tensions with the United States over funds hidden away in Swiss banks. The Swiss government announced Nov. 16 that the Federal Council, the government’s executive arm,…
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Is Domestic Asset Protection Dead?
There has been quite a bit of buzz about a recent bankruptcy case involving an Alaska asset protection trust. However, the case merely confirms a weakness in the use of domestic asset protection trusts that was obvious even before this case. Domestic asset protection trusts (DAPTs) promise the holy grail of creditor protection - a…
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