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IRS to Obtain US Bank Information on Finnish Residents with US Bank Accounts

Finland, USA - May 23 2019 On 1 May 2019, the US Department of Justice (DOJ) announced that the IRS had obtained a court order authorizing the service of “John Doe” summonses on…

Christopher Murrer, Elliott H. Murray, John Richard Cacharani.

North America Tax News and Developments - September 2018

USA - September 20 2018 On September 13, 2018, Treasury and the IRS released proposed regulations under section 951A. As of the date of this newsletter, the proposed…

Brandon King, Erik J. Christenson, Melinda R. Phelan, Michael Farrell, Moiz Shirazi, Paula R. Levy, Robert Hammill.

OVDP Compliance Campaign Rollout

USA - June 9 2017 The IRS Large Business and International Division recently rolled out several compliance campaigns, one of which is devoted to certain applicants of…

Daniel W. Hudson.

Final Reporting and Recordkeeping Requirements for Foreign-Owned Disregarded US Entities

USA - January 23 2017 The IRS published final regulations that address reporting and recordkeeping obligations of US disregarded entities (e.g., single member LLCs) wholly…

Paul F. DePasquale.

PFIC: Determining Ownership and Reporting Requirements Under New Regulations

USA - January 13 2017 On December 27, 2016, the US Treasury Department and IRS published final regulations (TD 9806) that provide guidance on determining ownership of a…

Daniel W. Hudson.