The OECD's Centre for Tax Policy launched a disclosure facility for reporting schemes that aim to circumvent the internationally agreed Common Reporting Standard (CRS) for automatic exchange of taxpayers' account information. The disclosure facility, which can be accessed through the Automatic Exchange Portal, is part of a three step process the OECD has created to…
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OECD Adds 7 More Countries To Its CbC Automatic Exchange Agreement
On 27 January 2017, 7 additional countries signed the Multilateral Competent Authority Agreement (MCAA) for the automatic exchange of Countryby-Country (CbC) reports. The signing took place at a ceremony held during the second meeting of the inclusive framework on BEPS on 26-27 January 2017. Those countries are: Gabon, Hungary, Indonesia, Lithuania, Malta, Mauritius and the…
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Is it Time to Expatriate? Your Neighbors Are.
The Treasury Department published the names of individuals who renounced their U.S. citizenship or terminated their long-term U.S. residency “Expatriated” during the fourth quarter of 2016. The number of published expatriates for the quarter was 2,365, bringing the total number of published expatriates in 2016 to 5,411. The total for the 2016 year breaks…
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Former Marine Denied Foreign Earned Income Exclusion for Failure to Make Election Timely
The Tax Court has concluded that a taxpayer wasn't entitled to a foreign earned income exclusion under Code Sec. 911(a) for the tax year at issue, because he failed to make a timely election under Reg. § 1.911-7(a)(2)(i), which provides that if the taxpayer is filing a late return and owes income tax after taking…
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