Even before the ink dries on the few agreements foreign banks may have entered into with the IRS to be a withholding agent for the US government, the rules are changing drastically. Major western European countries have already entered into agreements with the United...
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Month: September 2012
New IRS Streamlined Procedure for Offshore Disclosures
On August 31, 2012, the IRS published the new procedures first announced on June 26 regarding offshore voluntary disclosures. This is essentially a recognition on the part of the IRS that there are certain “no brainer” fact scenarios which qualify for relief from the...
ABA Taxation Section Vents About OVDI Uncertainty
This past weekend, the powerful and influential Taxation Section of the American Bar Association met in Boston and to no one’s surprise, the offshore voluntary disclosure initiative was a front and center focus which practitioners used to voice concern over the issues...