The DOJ petitioned the U.S. District Court for the Western District of North Carolina to authorize IRS summonses to uncover the identities of Finnish residents using U.S.-issued payment cards in Finland.

Effective immediately new US legislation will tax certain US beneficiaries of non-US trusts on their use of trust property

All United States persons who have a financial interest in or signature or other authority over foreign financial accounts (including bank, securities or other types of financial accounts, as well as debit and prepaid credit card accounts, in a foreign country), worth in the aggregate over $10,000 must file each calendar year a Report of Foreign Bank and Financial Accounts ("FBAR").

As we reported recently, earlier this year representatives of the U.S. Internal Revenue Service ("IRS") indicated informally that U.S. investors in foreign private equity and hedge funds are required to report annually their fund interests on Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (an "FBAR").

Much needed guidance on the Foreign Account Tax Compliance Act (‘FATCA') provisions of the HIRE Act is expected by the end of the first quarter of 2011.

The IRS and Treasury published final regulations (T.D. 9806) that provide guidance on determining ownership of a passive foreign investment company (PFIC)...

Kat Saunders Gregor, Ropes & Gray tax partner and co-founder of the tax controversy group, examines the influx of new anti-abuse provisions around the world.

Proposed amendments to the Income Tax Act (Canada) (ITA) will provide relief from Canadian payroll withholdings for many non-resident employers whose employees work in Canada on a temporary or short-term basis.

Switzerland will now more liberally permit disclosure of bank account information to the U.S. government without advance notice to the account owner.

As the end of the year nears, a U.S. subsidiary may try to repatriate cash to its foreign parent. Repatriation may occur in several different methods with each having advantages and disadvantages.

In a statement issued on March 30th, the U.S. Treasury Department announced that it will soon be issuing proposed regulations that will require foreign-owned, single-member LLCs to disclose to the IRS their beneficial owners.

The US Department of Commerce (Commerce) has broken with precedent and chosen to apply countervailing duties to imports from a non-market economy (NME) nation. On October 18, 2007, Commerce announced its affirmative final determinations in the antidumping and countervailing duty (i.e., anti-subsidy) investigations of coated free sheet paper imports from Indonesia, Korea, and the People’s Republic of China (PRC).

The IRS recently released Revenue Procedure 2026-25, which establishes a transfer tax safe harbor for certain contributions to Trump Accounts.

Plans that do not already contain loan and/or hardship provisions can also make loans or hardship distributions without formally amending the plan, provided that the plan is amended to provide for those loans or hardship distributions by the end of its plan year beginning in 2013.

§ 2801 of the Internal Revenue Code of 1986, as amended (the "Code") imposes a tax a U.S. citizen or resident who receives a "covered gift" or "covered bequest" from certain individuals...

On August 17, 2017, the Protocol amending the Convention for the Avoidance of Double Taxation and the Prevention of Fraud and Fiscal Evasion between Belgium and Mexico was published in Mexico's Official Journal...

Following on from the second part in this series, which looked at the proposal under Pillar One, the third and penultimate part in this series will examine the proposal under Pillar Two.

The French government estimates that the DST would raise approximately 500 million Euros per year.

Almost two years ago, the Organisation for Economic Co-operation and Development launched a radical and far-reaching review of the international tax system.

On February 27, 2013, the Tax Treaty signed between Mexico and Latvia and its Protocol were published in the Mexican Official Gazette.