Searching Content by Jay Rubinstein from Withers LLP ordered by Published Date Descending.
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Protocol Amending US/Swiss Tax Treaty Takes Effect
The protocol amending the United States Tax Treaty with Switzerland has been ratified by the United States and began to take effect as of 20 September 2019.
4 Oct 2019
IRS Releases New Procedures And Relief For Expatriating Taxpayers To Come Into US Tax Compliance
The IRS released new Relief Procedures for Certain Former Citizens which provide an alternative means for individuals who have expatriated or intend to expatriate to satisfy their US tax compliance certification process.
United States
24 Sep 2019
US Senate To Consider Loosening Restrictions On Exchange Of Information Between The US And Switzerland
The protocol proposing to amend the United States Tax Treaty with Switzerland was cleared by the US Senate Foreign Relations Committee on June 25, 2019.
12 Jul 2019
Foreign Grantor Trusts, US Situs Assets And 'Check The Box' Planning Under The US Tax Reform Act
The recently enacted US Tax Reform Act has repealed an exemption that may affect the way foreign grantor trusts ('FGTs') hold US situs assets potentially benefiting US (and also possibly non-US)...
19 Mar 2018
Recent IRS Policy Shift Requires Taxpayers To Reevaluate Decisions Made As To Previously Undisclosed Offshore Accounts And Assets
The US voluntary disclosure landscape has changed dramatically over the last 12 months.
United States
2 Jul 2015
US Announces Changes To The Offshore Voluntary Disclosure Programs
The IRS announced major changes to its offshore voluntary compliance programs, resulting in new guidance for taxpayers overseas and those in the US.
29 Jun 2014
Options Remain For US Taxpayers With Undisclosed Accounts
With the threat of exposure looming over the heads US taxpayers with undisclosed accounts, particularly in light of the Swiss bank voluntary disclosure programme and other recent efforts by the US authorities to combat tax evasion, the need to regularise has never been more urgent.
21 Sep 2013
The Legal Implications Of "United States v. Windsor"
The United States Supreme Court recently issued two landmark decisions on same-sex marriage.
United States
29 Jul 2013
FATCA – Registration Portal Delayed And Certain Deadlines Extended
The Internal Revenue Service recently announced revised timelines in connection with the staged implementation of the various due diligence, verification, withholding, and reporting requirements contained in IRC sections 1471 – 1474.
United States
28 Jul 2013
Final FATCA Regulations Released
The US Treasury Department has now released the long-anticipated final FATCA regulation.
18 Feb 2013
Over The Fiscal Cliff And Back Again - Highlights From The American Taxpayer Relief Act Of 2012
After briefly plunging over the "fiscal cliff" – the combination of tax increases and spending cuts that automatically came into effect on January 1, 2013 – Congress quickly passed the American Taxpayer Relief Act of 2012.
United States
14 Jan 2013
IRS Extends FATCA Implementation Deadlines (For The Last Time?)
In response to continuing concerns raised by foreign financial institutions, the IRS has issued new guidance further delaying a number of the FATCA implementation deadlines in the form of Announcement 2012-42 (the "Announcement"), offering FFIs much needed additional time to prepare.
United States
8 Nov 2012
United States And United Kingdom Sign Bilateral Agreement To Implement FATCA
On 12 September 2012, the Governments of the United States and the United Kingdom signed the first bilateral agreement to implement the US Foreign Account Tax Compliance Act.
30 Sep 2012
IRS Revised Guidance On 2012 Voluntary Disclosure Program
The IRS has simultaneously tightened the eligibility requirements to participate in the 2012 Offshore Voluntary Disclosure Program.
United States
15 Jul 2012
Voluntary Disclosure, Going Forward
On January 9, 2012, the IRS announced a new Offshore Voluntary Disclosure Program (the ‘OVDP’) that gives taxpayers with unreported foreign accounts a chance to come clean while mitigating the risk of criminal prosecution, noting that ‘the risk for people who do not come in continues to increase.’
United States
24 Jan 2012
Relief For US Citizens Residing Abroad
The IRS has released additional guidance applicable to US citizens and dual citizens of the US and another country residing outside the US in the form of FS 2011-13 (the "Guidance").
United States
4 Jan 2012
UK £30,000 Remittance Basis Charge Is Creditable Tax For US Taxpayers
The US Internal Revenue Service has now issued Revenue Ruling 2011-19, which rules that the UK remittance basis charge, currently £30,000, is creditable for US income tax purposes.
15 Sep 2011
You Gotta Have Good Faith - Or At Least Non-Willfulness
IRS Voluntary Disclosure Update Provides Extension to Submit Required Material to the IRS, Guidance for Opting Out of a Voluntary Disclosure, and a Reduced Penalty for Certain Foreign Residents
United States
16 Jun 2011
IRS Announces Reduced Penalties And Extension Of Time To File Under Voluntary Disclosure Programme
The first major change is a new reduced 5% penalty regime applicable to certain citizens and green card holders living outside of the United States.
United States
15 Jun 2011
FATCA Update
At a time in which the Foreign Account Tax Compliance ("FATCA") provisions of the "Hiring Incentives to Restore Employment Act of 2010" ('HIRE Act") have been coming under increasing criticism within the EU and Asia due to concerns that these provisions will result in significantly increased compliance costs for financial institutions, the IRS has released further guidance in the form of Notice 2011-34 (the "Notice").
19 Apr 2011
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