International Taxation

24
Mar

How U.S. Foreign Information Reporting applies to Your Cross Border Holdings

By: Michael J. Tedesco As another filing season is upon us, it is important to be aware of the extensive information reporting associated with holding assets outside of the U.S.  Failing to file necessary information returns or filing incomplete information returns can result in substantial penalties. FBARS – U.S. Persons, meaning individuals and entities, with a financial interest in or

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29
Dec

Andreozzi Bluestein Attorneys Speak on Federal and State Compliance Issues

Buffalo Law Journal’s Michael Petro interviewed Andreozzi Bluestein’s Senior Associate Michael Tedesco and Associate Heather Schmidt on federal and state compliance issues for his Tax Law Special Report. Petro’s federal article discusses recent trends in foreign bank reporting issues for both U.S. citizens and international banks. The IRS began allowing taxpayers to come forward with respect to their foreign accounts

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3
Aug

Law Creates New Due Dates for FBAR and Other Tax and Informational Returns

By: Heather Schmidt On Friday, July 31, 2015, President Obama signed H.R. 3236, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 into law.  In addition to temporarily extending funding for Federal-aid highway and infrastructure programs, the law also sets forth new deadlines for certain tax returns and informational filings.  Among the notable changes to the revenue

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16
Jan

Taxpayer Advocate Service Criticizes IRS’s Offshore Voluntary Disclosure Programs in 2014 Congressional Report

By: Heather L. Schmidt To combat money laundering and evasion of U.S. income obligations through the use of offshore accounts, Congress imposed a requirement on all United States taxpayers to annually file a Report of Foreign Bank and Financial Accounts (“FBAR”)[1] disclosing interests in accounts held outside of the U.S. where the aggregate balances exceed $10,000.  However, in 2002 the

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14
Jan

Federal Court Approves U.S. Government Issuance Of John Doe Summonses

By: Michael J. Tedesco A Federal Judge recently approved the Internal Revenue Service’s issuance of what is known as a “John Doe” summons¹ to several entities in the U.S who utilized the services of Sovereign Management & Legal Ltd. (“Sovereign”). These entities include FedEx, DHL, UPS, Western Union, the Federal Reserve Bank of New York, Clearing House Payments Company LLC

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24
Jul

Recent Revisions to the IRS Offshore Voluntary Disclosure Programs

By: Randall P. Andreozzi Recent revisions to the IRS Offshore Voluntary Disclosure Programs illustrate that the Service is becoming more aggressive and less tolerant with those taxpayers who have not yet come forward to report their interests in foreign bank accounts. The IRS on June 18, 2014, published new Streamlined Filing Compliance Procedures. The new Programs – one for U.S.

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25
Jun

IRS Makes Significant Changes to the Offshore Voluntary Disclosure Program and Streamlined Voluntary Disclosure Program

By: Michael J. Tedesco On June 18, 2014, the Internal Revenue Service (“IRS”) announced significant changes to the offshore voluntary disclosure programs. As part of the announcement, the IRS has expanded the 2012 Streamlined voluntary disclosure program to allow U.S. residents to participate in a version of that program. Additionally, the IRS has made several changes to the 2012 Offshore

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17
Mar

Tax Anxiety – Good News & Bad News

With the upcoming hype surrounding taxes as April 15th approaches, anxiety increases for those in tax trouble. A significant number of people have been contacted by the taxing authorities about missing tax returns, or are nervously anticipating such contact. Others already have an assessed liability and are facing enforced collection action. What many individuals who have not filed do not realize

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13
Nov

Department of Justice Reminds Swiss Banks That Time is Running Out to Participate in a Non-Prosecution Agreement

In a November 5, 2013 post in The Justice Blog, the United States Department of Justice (DOJ) Tax Division issued a reminder to Swiss Banks that their time is running out to enter into a non-prosecution agreement with the United States.  Eligible Swiss Banks have until December 31, 2013 to seek a non-prosecution agreement with the United States.  This program is just

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1
Apr

Shedding Some Light on the PFIC Regime

By: Kenneth A. Grossberg Today, United States investors in foreign corporations often find themselves with an unknown or unexpected problem.  In particular, investors in mutual funds organized outside of the United States have run into problems with the Passive Foreign Investment Company (“PFIC”) rules.  As the application of these rules can result in severe tax consequences to the unwary and unprepared,

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