The role of Form 5471 in the U.S. international tax system
On December 4, 2025, the IRS and the Treasury Department issued Notice 2025-68 Notice of Intent to Issue Regulations with Respect to section 530A Trump accounts (‘Notice’). The Notice: * provides an overview of how Trump accounts will operate; * sets out questions...
By Gina Gatchell, Director In 2010 I received a call from a very upset US citizen about the enactment of the Foreign Account Tax Compliance Act. She sent me the article she had just read, which set out the future of information reporting by institutions outside the...
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,...
The National Taxpayer Advocate’s Objectives Report to Congress for Fiscal Year 2016 contained the Taxpayer Advocate’s eleven areas of focus for 2016. Statement Area of Focus #4, The IRS’s Implementation of FATCA Has in Some Cases Imposed Unnecessary...
