International Taxation

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 …
Lowering the Bar for Willfulness for FBAR Penalties
Listen The IRS has authority to assert FBAR civil penalties.  Before delving into the FBAR abyss, this is a good time to debunk some FBAR myths.  First, there is no such thing as an FBAR penalty within the Offshore Voluntary Disclosure Program (OVDP).  The FBAR penalty exists only outside of the OVDP framework.  However, there …
Add the Letter ‘T’ to FATCA, and No One’s Getting Fat Except the IRS
Listen In 2010 President Obama signed P.L. 111-147, the Hiring Incentives to Restore Employment Act. The purpose of the law is in its eponymous title, but the IRS got into the act with the Foreign Account Tax Compliance Act (FATCA) provisions. FATCA is an attempt by the IRS to “improve reporting compliance” — translation: “widen the …
Employment Taxes And The Self-Employed Global Worker – So “Un”Happy Together – Part I (4)
Listen I. Domestic Administration of Social Security Taxation and the Scope of International Coordination – continued c. The Third Aspect: Taxation of Benefits Up to 85% of social security benefits received by United States citizens and residents are included in income and subject to taxation, depending on the level of benefits, tax filing status, and …