Month: October 2015

By Sanford Millar of MillarLaw A Professional Corporation On Sunday, October 25, 2015

The IRS recently published published an internal guideance on who must report interests in foreign corporations and the penalties for non-compliance. The timing of the guideance is important as the first “information exchange” and “information reporting” under the Foreign Account Tax Compliance Act, “FATCA” occurred September 30,2015.  The IRS and Justice Deptartment will now be … Continue reading Who Must Report Foreign Corporations

By Sanford Millar of MillarLaw A Professional Corporation On Sunday, October 18, 2015

The following Notice from the IRS reiterates the enforcement focus on offshore accounts.  Anyone with an unreported offshore account needs to consult counsel and discuss their compliance options under the “attorney-client” privilege. The IRS has left out of the Notice whether it will treate identified non-compliant taxpayers as “willful” for FBAR penalties and for civil … Continue reading Ofshore Accounts Still Focus of IRS Enforcement

By Sanford Millar of MillarLaw A Professional Corporation On Sunday, October 11, 2015

At a recent tax conference a senior Justice Department official reaffirmed thte commitment of the U.S. Department of Justice to continue offshore enforcement efforts. As is widely reported the official stated: “We are well beyond Switzerland at this point,” she said, citing enforcement announcements concerning India, Israel, Liechtenstein, Panama, the British Virgin Islands, and, most … Continue reading Justice Department Focusing on Offshore Account

By Sanford Millar of MillarLaw A Professional Corporation On Sunday, October 4, 2015

It’s Here; The Automatic Exchange of Information Under FATCA Began September 30th The IRS has announced that as of September 30, 2015 it will implement the automatic exchange of tax information as set forth in the Foreign Account Tax Compliance Act, (FATCA). The IRS Commissioner in announcing the implementation of the automatic exchange of information … Continue reading It’s Here; The Automatic Exchange of Information Under FATCA Began September 30th