Senate Votes to Amend Bill to Crack Down on Foreign Financial Institutions Aiding Tax Evasion

On March 8, 2012, the Senate amended the surface transportation bill (S. 1813) to include provisions that would allow the United States Treasury to prohibit United States banks from honoring credit cards or accepting wire transfers from foreign banks that the Treasury considers to “significantly impede” United States tax enforcement. Under the bill, the Treasury’s…

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Mexico, France, Germany, Italy, Spain, and the United Kingdom Agree to Share Bank Information with the United States

Spurred by the requirements set forth in the Foreign Account Tax Compliance Act (FATCA), on February 8th, the governments of France, Germany, Italy, Spain, the United Kingdom, and the United States agreed to implement a system for government-to-government sharing of bank account information of their citizens and residents. On February 24, it was reported that…

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Foreign Financial Institution FATCA Reporting Guidelines Published

In 2010, the U.S. government enacted the Foreign Account Tax Compliance Act (FATCA), containing provisions that would require, starting in 2013, foreign financial institutions (FFIs) to provide to the IRS the personal information of any United States persons holding accounts at that FFI. See http://rroyselaw.com/blog1/2012/01/12/third-offshore-voluntary-disclosure-program-announced-by-irs/.The Proposed Treasury Regulations published on February 8th push the effective…

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Corporate Reporting of Transactions Affecting Basis

Under Section 6045B of the Internal Revenue Code of 1986, as amended (the “Code”) many corporations are required to file a new return (Form 8937) with the IRS in connection with non-dividend distributions and other corporate actions affecting stock basis. More specifically, starting in 2011, the issuer of “specified securities” shall file a return with…

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