The IRS has a contingency plan in place, the Lapsed Appropriations Contingency Plan (‘contingency plan’), in preparation for the US government shutdown which is currently occurring. The 120-page document details what areas of the IRS will shut down, and what...
Eight years after the Foreign Account Tax Compliance Act (FATCA) was enacted as part of the 2010 Hire Act, the Eastern District of New York has prosecuted an executive of Loyal Bank for wilfully circumventing the reporting requirements of FATCA. The executive,...
Section 988 of the Internal Revenue Code Treatment of Certain Foreign Currency Transactions taxes certain transactions defined as ‘Section 988 transactions’. The general rule is that the disposition of any non-functional currency will be treated as a section 988...
United States citizens and other residents of the United States with foreign trusts requiring the annual filing of such forms as Form 3520 and Form 3520-a have been selected by the IRS Large Business and International division (LB&I) for six compliance campaigns....
The Internal Revenue Service has announced the end of the Offshore Voluntary Disclosure Program (OVDP). The deadline for full and final submissions has been announced as 28 September 2018. The OVDP program has been around in one form or another since 2009. It is...
