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Monthly Archives: July 2013

IRS Cancels Furlough Day for July 22nd :)

We originally posted on Friday, April 19, 2013, IRS Begins Furlough Notice which include a discussion that the IRS would be closed on July 22, 2013

The Internal Revenue Service has canceled one of its five furlough days planned for this year under the automatic spending cuts known as the sequester.

Acting IRS Commissioner Daniel Werfel told employees in a memo that the agency had would no longer force employees to take unpaid leave on July 22.

So the IRS will be OPEN on Monday!

Having Trouble Contacting the IRS to Resolve Your Tax Problem?

Contact the Tax Lawyers at Marini & Associates, P.A.
 

for a FREE Tax Consultation at:
Toll Free at 888-8TaxAid (888 882-9243).

 

Read more at: Tax Times blog

Swiss Banks To Turn Over Information To IRS!

The Swiss government has cleared the way for a dozen banks to turn over client data to the IRS despite an earlier ruling from Switzerland’s Federal Supreme Court.


Although the IRS pushed the implementation of certain FATCA key deadlines from January 1st to July 1st, 2014, as we posted in IRS Delays FATCA Registration for Six Months, several Swiss banks are ready to turn over their records over to the IRS.

The Swiss Federal Court has dismissed protests by American clients of Credit Suisse that their account data should not be disclosed to the US Internal Revenue Service (IRS).


The IRS and Justice Department have become very adept at finding unreported offshore accounts. By targeting banks and individual bankers, the IRS is often able to leverage the threat of jail in return for cooperation and the release of customer records. The IRS also has several other tools in its arsenal.

On Tuesday, June 18, 2013, we posted DOJ Requests Identification of US Depositors in Bank Weglin - Time To Come Clean? where we discussed that the US Department of Justice has submitted another administrative assistance request to the Swiss authorities, this one demanding the identification of American clients of the private bank Wegelin who were beneficiaries of asset management companies between 2002 and 2012.

Two weeks previous to this Bank Wegelin, the private bank Julius Baer was also notified that it was subject of a similar request.

U.S. authorities have more than a dozen banks under formal investigation, including:

  • Credit Suisse,
  • Julius Baer,
  • the Swiss Branch of HSBC,
  • Pictet and
  • Zuercher Kantonalbank and
  • Basler Kantonalbank.

Many U.S. taxpayers have been sitting on the fence waiting to see what happens with FATCA or the outcome of this case. That could prove to be a very costly mistake!

 

Once your name is turned over to the government, its probably too late to take advantage of any of the amnesty programs. Customers with accounts at Israel based Bank Leumi learned that lesson the hard way.

Because the IRS operates it’s amnesty programs on a “first contact” basis, its important to approach the IRS before they find you or before your name is turned over.

Undeclared Income from a Swiss Bank Account?

Contact the Tax Lawyers
at Marini & Associates, P.A.
 
for a FREE Tax Consultation
or Toll Free at 888-8TaxAid (888 882-9243).


 
Source:

Swissinfo

Read more at: Tax Times blog

List of Changes in Notice 2013-43 – FATCA Delay.

We posted IRS Delays FATCA Registration for Six Months!  on July 12, 2013, Which discusses IRS 2013-43, which provides for a Six-Month Extension for FATCA Withholding! 

This notice provides a six-month extension for when withholding will begin (i.e., payments after June 30, 2014) and for implementing new account opening procedures as well as related requirements to comply with FATCA.

The significant changes that can be found in IRS Notice 2013-43 are:                
  1. FATCA withholding delayed until 7/1/2014
  2. Customer onboarding delayed until 7/1/2014
  3. Definition of a preexisting account has been extended to 7/1/2014
  4. Grandfathered obligation extended to 7/1/2014
  5. For withholding agents other than PFFIs (for example, USFIs), due diligence on preexisting obligations has been postponed by 6 months. Prima facie FFIs now need to be documented by 12/31/2014; other entities and individuals need to be documented by 6/30/2016
  6. FFI registration delayed by 6 months.
  7. Portal comes out 8/19/2013. To get on initial FFI list must be registered by 4/25/2014 to get on initial list that will be published on 6/2/2014
  8. Due diligence for PFFIs extended by 6 months for each category. However, enhanced review for high-value individuals has been extended by 1 year to 12/31/2015
  9. Extension of all QI, WP, and WT agreements by 6 months
  10. Current W-8s and documentary evidence expiring on 12/31/2013 will now expire on 6/30/2014

 

Undeclared Income from a Foreign Account?
Contact the Tax Lawyers
at Marini & Associates, P.A.
 
for a FREE Tax Consultation
or Toll Free at 888-8TaxAid (888 882-9243). 

Source:

Tomer Siegal

Read more at: Tax Times blog

IRS Delays FATCA Registration for Six Months!

We posted on Wednesday, July 10, 2013 "FACTA Registration is Set To Begin in July!" which discusses that starting on July 15, 2013, the United States is scheduled to begin registering foreign financial firms
with U.S. customers for a new anti-tax evasion law know as FATCA. Today the IRS issued Notice 2013-43, which provides Six-Month Extension for FATCA Withholding! 
This notice provides a six-month extension for when withholding will begin (i.e., payments after June 30, 2014) and for implementing new account opening procedures as well as related requirements to comply with FATCA.
In the preamble to the final regulations, Treasury and the IRS announced their intent to create a FATCA registration website, which would serve as the primary way for FFIs to interact with the IRS to complete the required registration, agreements, and certifications. The preamble stated that the FATCA registration website would be accessible to FFIs no later than July 15, 2013.

After approval of its registration, each PFFI and registered deemed-compliant FFI would be assigned a global intermediary identification number (GIIN), which would be used both for reporting purposes and to identify the FFI’s status to withholding agents. The preamble provided that the IRS would electronically post the first list of PFFIs and registered deemed-compliant FFIs (IRS FFI List) on December 2, 2013, and would update the list on a monthly basis. To ensure inclusion on the December 2013 IRS FFI List, FFIs would need to register by October 25, 2013.  
 

Modification of Phased Timeline for Implementation  

Comments have indicated that certain elements of the phased timeline for the implementation of FATCA present practical problems for both U.S. withholding agents and FFIs.  

In addition, while comments from FFIs overwhelmingly supported the development of IGAs as a solution to the legal conflicts that might otherwise impede compliance with FATCA and as a more effective and efficient way to implement cross-border tax information reporting, some comments noted that, in the short term, continued uncertainty about whether an IGA will be in effect in a particular jurisdiction hinders the ability of FFIs and withholding agents to complete due diligence and other implementation procedures.  

In consideration of these comments, and to allow for a more orderly implementation of FATCA, Treasury and the IRS intend to amend the final regulations to postpone by six months the start of FATCA withholding, and to make corresponding adjustments to various other time frames provided in the final regulations, as described in section III 

In addition, as described in section IV below, Treasury and the IRS intend to provide a list of jurisdictions that will be treated as having in effect an IGA, even though that IGA may not have entered into force as of July 1, 2014.

Undeclared Income from a Foreign Bank or Brokerage Account?
Contact the Tax Lawyers
at Marini & Associates, P.A.
 
for a FREE Tax Consultation
or Toll Free at 888-8TaxAid (888 882-9243).

 

 

Read more at: Tax Times blog

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