Don’t Mistake “GIIN” For Gin Or You May Suffer More Than Just a Hangover!
In a recent blog entitled, “FATCA GIIN January 2015 FFI Registration Analysis … by the numbers,” Professor William Byrnes provides a brilliant commentary on the IRS’s publication of its first FATCA GIIN list of the new year (published on New Years Day!). The FATCA GIIN list is a list of “approved FFIs (Foreign Financial Institutions)” that have registered […]
US Automatic Exchange of Bank Information to 86 Foreign Countries in 2015
In a recent blog entitled, “US Automatic Exchange of Bank Information to 86 Foreign Countries in 2015,” Professor William Byrnes lists the countries with which the U.S. has an automatic exchange relationship. There are a total of 86. The article can be found on Professor Byrnes’ International Financial Law Prof Blog.
Application of Foreign Earned Income Exclusion to Civilian Contractors Working In Combat Zones (Part II)
This is Part II of a two-part blog series. After establishing that they have a tax home in a foreign country, taxpayers must still establish that they satisfy the 330 day physical presence test or the bona fide residence test. See IRC section 911(d)(1). I. 330 Day Physical Presence Test The 330 day physical presence […]
Application of Foreign Earned Income Exclusion to Civilian Contractors Working In Combat Zones (Part I)
This blog addresses the foreign earned income exclusion rules as they apply to civilian contractors, and other civilian employees, who work in foreign country combat zones. By “civilian,” I am specifically referring to individuals who are not employees of the United States or any agency of the United States. I. IRC Section 911 Foreign Earned […]
What Should A Swiss Banker Charged With Offshore Tax Evasion Do In The Wake of Raoul Weil’s Astonishing Acquittal?
The acquittal of Raoul Weil, the only Swiss banker to have prevailed over the U.S. government in an offshore tax evasion case, has become a source of inspiration for dozens of others who find themselves in a similar situation – indicted and living in Switzerland. As a result, many have become emboldened to come out […]
IRS Unveils Updated List of Foreign Financial Institutions Or Facilitators That Trigger 50% Offshore Penalty In OVDP
The IRS recently updated the list of foreign financial institutions that trigger an enhanced penalty in OVDP. While the offshore penalty is generally 27.5% of the highest year’s aggregate balance during an eight year look-back period, to the extent that the taxpayer has an undisclosed foreign financial account with any one of the following banks at the time […]