International Taxation

Mad As Hell And Not Going To Take It Anymore: Two Brave Women Sue Canadian Government Over Controversial FATCA Deal
Listen Is Ottawa violating Canadians’ constitutional rights to help the U.S. collect taxes? According to two Ontario women, it is. Two women are suing the Canadian government over a controversial deal in which Canada has agreed to share the tax information of U.S. persons who are Canadian residents with the IRS. On its face, the deal …
Reciprocal FATCA Reporting: Treasury Issues Proposed Rules To Enhance Financial Transparency
Listen On July 30, 2014, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) proposed rules requiring U.S. financial institutions to collect “Customer Due Diligence” information. The purpose of these proposed rules is to prevent unscrupulous individuals from using anonymous companies to engage in or launder the proceeds of illegal activity in the U.S. financial sector. …
What Should I Do If My Non-Consenting Swiss Bank Account Becomes The Target of an IRS Group Request?
Listen Suppose that you have an undisclosed offshore account with XYZ Bank, a Swiss bank. You received a declaration of consent from XYZ Bank requesting your consent to disclose your account information to the IRS directly. You refused. Because you did not consent, your account became subject to aggregate reporting by XYZ Bank. Pursuant to the Swiss-U.S. FATCA Agreement, …
A Clash of Mammoth Proportions: In One Corner, Switzerland’s Tradition of Bank Secrecy And In The Other, FATCA
Listen While the Swiss banking system’s reputation for hiding numbered bank accounts under a cloak of anonymity was once considered sacrosanct, the seal was broken on its banking secrecy back in 2013 when it signed an international agreement with the OECD (Organization for Economic Cooperation and Development) to fight tax evasion.  Since then, other international …
The End of Swiss Banking Secrecy?
Listen “There is only one thing in the world worse than being talked about, and that is not being talked about.”[1]  Oscar Wilde’s insightful observation about humankind’s proclivity toward public recognition does have exceptions.  For a variety of reasons, men and women throughout the world have often sought confidentiality in their financial affairs, chiefly through …