Taxpayers Said to Fear Disclosing Assets as Foreign Bank Crackdown Continues

The Internal Revenue Service’s intense effort to get taxpayers to tell the government about their offshore assets may be running into difficulties even as IRS continues its crackdown on foreign banks that help taxpayers hide those assets…

Treasury, IRS Likely to Seriously Consider E.U. Letter on Foreign Account Tax Compliance Act Concerns, Practitioners Say

The United States is likely to carefully consider the European Union’s letter voicing concerns about the Foreign Account Tax Compliance Act and suggesting “synergies” between the EU Savings Directive and the new U.S. statute…

IRS Unveils Eagerly Awaited Foreign Account Tax Compliance Act Guidance; Practitioners Say Many Challenges Remain

The Internal Revenue Service April 8 unveiled its eagerly awaited second notice on the Foreign Account Tax Compliance Act, offering what practitioners said is welcome guidance under the new law that requires foreign banks to disclose their U.S.-owned accounts or face a 30 percent withholding tax in some cases…

FinCEN Unveils Final Report of Foreign Bank Account Regulations, Clarifies Definition of Signature Authority

The Financial Crimes Enforcement Network (FinCEN) Feb. 23 unveiled final rules on the scope of persons required to file the Report of Foreign Bank Account (FBAR), clarifying the definition of those required to file because they have signature authority over an account and making a host of other changes…

Dozens of Stakeholders Raise Concerns on Burdens of FATCA Regime

Dozens of foreign banks, foreign insurance companies, professional associations including several based in Washington, and other stakeholders around the world are asking the Internal Revenue Service for exceptions and clarifications…

Government Dismisses Criminal Tax Case Against UBS, Prompting Questions about IRS’s Next Overseas Target

The U.S. government’s dismissal of a criminal information against the Swiss bank UBS AG that was filed with the U.S. District Court for the Southern District of Florida Oct. 22 has led to questions as to which…

BNA INSIGHTS: The Developing Aftermath of the UBS Affair: A New Tax Order

The high-profile UBS tax evasion case has been especially attractive to the popular press the past…

BNA INSIGHTS: IRS Offshore Accounts Disclosure Program: A Critical Assessment After One Year

Exactly one year ago, the tax world watched as the Internal Revenue Service conducted what may have been the most extraordinarily…

BNA INSIGHTS: Passive-Aggressive: IRS Releases Initial Guidance on FATCA Rules

Any attorney who has practiced law for some period of time has encountered co-counsel or opposing counsel who release a thick set of…

U.S., Switzerland Say Deadline for Processing UBS Accounts Met, Handover Not Yet Done

GENEVA—Both the U.S. and Swiss governments said Aug. 26 that Switzerland has met its obligations under a landmark August 2009 agreement with the United States to review some 4,450 secret accounts held by U.S. taxpayers with Swiss banking giant UBS, but Swiss officials admitted…

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