Received a FATCA Letter from Your Foreign Bank?

- By : Parag Patel

…compliance problems. Below are some Frequently Asked Questions received from our clients: Why did I receive a FATCA letter? If you have received a FATCA letter, you may already be…

Beware of FATCA Letters

- By : Parag Patel

…of these letters? It’s important not to ignore the letter, which usually arrives with a Form W-9 or W-8. To grossly simplify the impact of FATCA, FATCA has pushed the…

IRS Letters and Notices Offering an Appeal Opportunity

- By : Parag Patel

…of the letter in order to appeal the proposed action with the Office of Appeals. Letter 525 – General 30 Day Letter You will get this letter with a computation…

Global Enforcement of FATCA: Something to Worry About

- By : Parag Patel

…authorities of the FATCA partner information on the U.S. accounts of residents of the FATCA partner.” With the Joint Statement, then, FATCA will become an instrument for U.S. bilateral automatic…

U.S. Signs FATCA Pacts with Malta, Netherlands, Bermuda, Jersey, Guernsey and Isle of Man

- By : Parag Patel

…updating information recently on FATCA. On Wednesday, the IRS posted the FATCA FFI List Resources and Support Information Web page to its FATCA Web site. In addition, the FATCA FFI…

FATCA Noncompliant Accounts may be Frozen or Blocked

- By : Parag Patel

Many of our clients with foreign accounts have received FATCA letters. The letters seek personal information regarding the account holder in order to comply with the US FATCA law. In…

India Expected to Sign FATCA Agreement Tomorrow

- By : Parag Patel

India is expected to sign an inter-governmental agreement (IGA) for the US tax compliance law Foreign Account Tax Compliance Act (FATCA) tomorrow. FATCA is aimed at combating possible tax evasion…

FATCA Enforcement Softens

- By : Parag Patel

Realizing the large administrative burden of FATCA, the IRS has announced a “soft opening” of FATCA and enforcement at the IRS’ discretion for an initial transitional period. FATCA, which was…

What is a “FATCA Compliance Certificate”?

- By : Parag Patel

…of the US government’s effort to address tax evasion. FATCA is rapidly becoming the global standard in the effort to curtail offshore tax evasion. FATCA REQUIREMENTS Put simply, under FATCA,…

New Jersey Division of Taxation Now Issuing Letter Rulings

- By : Parag Patel

The New Jersey Division of Taxation recently announced that it will implement new procedures for taxpayers to obtain letter rulings. Similar to letter rulings issued by the Internal Revenue Service…

What FATCA Means to You and Your Investments

- By : Parag Patel

…effort to address tax evasion. FATCA is rapidly becoming the global standard in the effort to curtail offshore tax evasion. FATCA REQUIREMENTS Put simply, under FATCA, financial institutions will have…

Swiss Government and US Government Announce New Program for Cooperation and Disclosure by Swiss Banks

- By : Parag Patel

…Applicable Period. These banks may request a Non-Target Letter based on satisfying certain conditions, including demonstrating the existence of an effective compliance program. A bank requesting a Non-Target Letter under…

Beware: India to sign FATCA agreement with US for sharing of information

- By : Parag Patel

…IRS in the U.S. While the threshold limit for reporting will be specified by the regulators in India based on FATCA regulations, institutions will have reporting requirements under FATCA, in…

India and US signed FATCA Agreement Today

- By : Parag Patel

…1, 2015. FATCA was signed by Revenue Secretary Shaktikanta Das and US Ambassador Richard Verma in New Delhi. “FATCA is a mutual effort to combat tax evasion and it would…

The Teeth of the Foreign Account Tax Compliance Act (FATCA)

- By : Parag Patel

The Foreign Account Tax Compliance Act (FATCA) is about disclosure and transparency, but in part is to catch Americans trying to stash money overseas. Controversially, FATCA orders every foreign bank…

Make Sure You have Filed FATCA Compliance Certifications

- By : Parag Patel

…complete a “FATCA Compliance Certificate”. The reason for the request is that India and the US signed an agreement to implement the Foreign Account Tax Compliance Act (FATCA), which allows…

American Citizens Abroad (ACA) writes letter to IRS Commissioner regarding unfair offshore asset treatment

- By : Parag Patel

letter calls upon Commissioner Shulman to answer these concerns promptly, as is his statutory duty. In the letter, ACA also asks how many of the reported 33,000 taxpayers who came…

New FATCA Enforcement Expected

- By : Parag Patel

The IRS has tightened its enforcement of the Foreign Account Tax Compliance Act (“FATCA”). FATCA was enacted in 2010 by Congress to target non-compliance by U.S. taxpayers using foreign accounts….

OVDI: Requesting issuance of a FBAR warning letter instead of penalties

- By : Parag Patel

…background, IRS agents should generally either issue the FBAR warning letter, Letter 3800, or determine a penalty. See IRM 4.26.17 for the Letter 3800 procedures. See below. Depending on the…

FATCA Repeal Fails

- By : Parag Patel

Last month US Senator Roger Wicker (R-Miss.) introduced a budget amendment SA 621 to repeal the Foreign Account Tax Compliance Act (FATCA) FATCA requires foreign financial institutions to disclose to…

Post IRS Audit Strategic Options: The IRS’ 30 Day Letter

- By : Parag Patel

…“30-day letter.” The 30-day letter is a form letter that sets forth the amount of the proposed adjustments to the taxpayer’s liability. Included with the 30-day letter will be the…

30-DAY LETTERS VS. 90-DAY LETTERS IN TAX AUDITS

- By : Parag Patel

…before the statute of limitations expires, the IRS will skip the 30-day letter and instead issue a 90-day letter (notice of deficiency). The 90 -day letter indicates a deficiency in…

Form 8938, FATCA, FBAR and penalties for all (including bankers)

- By : Parag Patel

…assets, which puts both at a disadvantage. Many foreign banks are lobbying the US Congress to change FATCA or FATCA regulations. In the meantime, beware that FATCA is the law…

Foreign Account Tax Compliance Act (FATCA) online registration program is launched

- By : Parag Patel

…to take before the Foreign Account Tax Compliance Act (FATCA), enacted in 2010, takes effect in July 2014 with steep penalties for firms that do not comply. FATCA requires foreign…

First Indictment for FATCA Violation Announced

- By : Parag Patel

…a full six months before the initial FATCA reporting deadline, sends a strong message of aggressive FATCA global enforcement. Over 100 countries have now signed or consented to sign FATCA

IRS Warning Letter Warns Foreign Business Owners About Section 965 Transition Tax Enforcement

- By : Parag Patel

…year ends (generally, 2017 and/or 2018). The Internal Revenue Service will address noncompliance through soft letters and examinations. We have seen a few of these IRS letters (Letter 6311) sent to…

How to Respond to an IRS CP3219N Notice of Deficiency (90-day letter)

- By : Parag Patel

…tax liability. A 90-day letter is a formal legal notice, sent by certified or registered mail. You can’t respond to a Notice of Deficiency with a letter. In fact, only…

Foreign Account Tax Compliance Act (FATCA): More Information Sharing Agreements Expected

- By : Parag Patel

FATCA was enacted in 2010 by Congress to target non-compliance by U.S. taxpayers using foreign accounts. FATCA requires foreign financial institutions (FFIs) to report to the IRS information about financial…

India Signs FATCA Model Intergovernmental Agreement to Share Account Information with the US

- By : Parag Patel

…on FATCA regulation, institutions will have reporting requirements under FATCA, in terms of threshold limits. As per FATCA, US persons need to report to IRS in the following scenarios: •…

FATCA-Compliant Institutions List Goes Online

- By : Parag Patel

…check on whether a foreign financial institution has registered for FATCA. FATCA was included as part of the US HIRE Act of 2010 and requires foreign financial institutions to provide…