Compliance Issues Tax Amnesty Tax Compliance

The White House Speaks on Panama Papers

Following a leak in April of the so-called “Panama Papers,” documents evidencing assets being hidden by shell companies owned by some of the world’s most powerful and influential leaders and…

Compliance Issues Tax Amnesty Tax Compliance

Panama Papers Reveal Hidden Assets of Worldwide Elite

Dubbed the “Panama Papers,” an extensive 11 million document trove from Panamanian law firm Mossack Fonseca was leaked to Süddeutsche Zeitung, Germany’s largest national subscription newspaper; it has been analyzed…

Internal Revenue Service Tax Compliance

Foreign Charities

Pursuant to Internal Revenue Code § 170, contributions to certain charitable organizations are tax-exempt.  Generally, contributions to foreign organizations are not tax-deductible.  Certain foreign organizations, however, can be treated as…

Internal Revenue Code Tax Compliance

Foreign Students and the Five Year Rule

It is not uncommon for foreign individuals from abroad to attend university in the United States on a F-1 Student Visa.  In general, nonresident aliens who are present in the…

FATCA Passive Foreign Investment Company

US Expatriates and PFICs

Traditionally, when a U.S. person would find themselves spending long times abroad and potentially living in a foreign country, they would start to make investments in the local economy.  Most…

Tax Compliance

U.S. Correspondent Banks Cut Ties with Mexican Institutions

A correspondent bank is a financial institution that provides services on behalf of another financial institution.  They can conduct business transactions, accept deposits and gather documents on behalf of the…

International Taxation OVDI Tax Amnesty

Tax Evaders Come Clean in Germany

In 2014, Uli Hoeness, a celebrity soccer manager in Germany, was sentenced to three and a half years in prison for evading € 28.3 million in taxes.  The case was…

Internal Revenue Service

IRS Phone Scam

As tax season approaches, taxpayers should be aware of an ongoing IRS phone scam.  Callers will generally contact taxpayers and represent themselves to be IRS agents and state that money…

Business Internal Revenue Code

Recent Changes to IRC § 1202 Small Business Stock Gains Exclusion

In December 2015, the Protecting Americans from Tax Hikes Act of 2015 (“PATH Act”) was passed by Congress and signed into law and with it made certain tax breaks permanent,…

FATCA OVDI Streamlined Procedure Tax Amnesty

More Banks Added to IRS’ Disclosure Blacklist

The IRS maintains a list of Foreign Financial Institutions or Facilitators, essentially a blacklist of institutions which have been determined to be complicit in evasion of U.S. taxes.  While taxpayers…

FATCA U.S. Withholding

FATCA: Upcoming Amendments

The Treasury and IRS are poised to amend regulations under Chapters 3 and 4 of the Internal Revenue Code regarding the Foreign Account Tax Compliance Act (“FATCA”).  These changes will…