Brazil Immigration

Brazilians Flock to Miami to Bear their Children

There has been an influx of affluent Brazilian families coming to Miami to bear their children due to the deep recession, swelling unemployment and crime rising in Brazil, and the…

FIRTPA

Congress Approves FIRPTA Reform

Congress amended the Foreign Investment in Real Property Tax Act of 1980 (“FIRPTA”) in the Omnibus bill that was passed last week. This opens the door to greater purchases by…

Switzerland

Swiss Bankers Association Publishes Dormant Accounts List Worth 44 Million

On December 16, the Swiss Bankers Association published a list online which includes the names, last know addresses and nationalities of approximately 2,600 owners of safe-deposit boxes and accounts that…

Compliance Issues Forms and Filings

Many IRS Return Due Dates Changed for 2015 Reporting Season (including FBAR) and Change to IRS Audit Period

The Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 was signed into law on July 31, 2015.  This legislation changes the IRS return due dates going forward…

Foreign Tax Preparation OVDI

IRS Issues New Rules for Offshore Voluntary Disclosure

The IRS has announced (IR-2014-73) changes to its offshore voluntary compliance programs. These changes provide new options for taxpayers residing overseas and in the United States come into compliance their…

Compliance Issues Foreign Tax Preparation Switzerland

Credit Suisse Agrees To $196 Million Settlement With The SEC

Credit Suisse Group AG agreed to pay $196.5 million and admit wrongdoing to settle U.S. Securities and Exchange Commission charges that it provided cross-border brokerage and investment advisory services to…

Compliance Issues Foreign Tax Preparation

New Rules for 2013 Tax Year PFIC Filing (Form 8621)

On December 30, 2013, the IRS published a package of proposed, temporary, and final regulations relating to Passive Foreign Investment Companies (“PFICs”) and their shareholders. The most significant component of…

Foreign Country Filing Considerations Foreign Tax Preparation

IRS Requires US Banks to report $10 or More In Interest on accounts held by nonresident Aliens

January 13th 2014 – Federal District Court Upholds IRS Regulations Requiring Interest of $10 or More to Be Reported by US Banks for Accounts held by Nonresident Aliens. A petition…

Foreign Tax Preparation

Ty Warner Pleads Guilty To Tax Evasion

H. Ty Warner, the man behind Beanie Babies, plead guilty to tax evasion in U.S. District Court.  Warner owes the government $53.6M in failure to file penalties and offshore account…

Compliance Issues Tax Amnesty

Zurich Bank Under US Investigation for Tax Evasion

Rahn & Bodmer Co. a Zurich Private Bank, Under U.S. investigation for aiding in American Tax Evasion One of the oldest private banks in Zurich, Rahn & Bodmer Co., has…