With the July 1, 2014, FATCA effective date quickly approaching, it is finally front page news. Practitioners who are following FATCA closely have noted that the emphasis has shifted slightly from the onerous and unfair injustice FATCA imposes on Americans abroad and...
Taking A Cooperative Approach To Your Legal Issues
Month: March 2014
Opt Out of Offshore Voluntary Disclosure Program? We Need To See the National Office Appeals Coordinated Issues Paper Now!
An emerging issue for practitioners engaged in the offshore voluntary disclosure arena is collecting intel on what exactly the field offices are being told by the National Office about how to resolve opt out cases. A client can choose to opt out at any time assuming...