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FATCA

Senator and others’ challenge to foreign account reporting regime dismissed

Senator and others’ challenge to foreign account reporting regime dismissed

Crawford, et al, v. Dept. of the Treasury, et al, (4/26/2016 DC OH) 117 AFTR 2d ¶2016-650 A district court has dismissed a suit brought by Senator Rand Paul (R-KY) and several individual plaintiffs challenging the Foreign Account Tax Compliance Act (FATCA) and Foreign Bank Account Report (FBAR) requirements. The court found that Senator Paul’s […]

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Proposed regs would modify FBAR filing rules for financial professionals

Proposed regs would modify FBAR filing rules for financial professionals

FinCEN news release, “FinCEN Proposes Revising FBAR Rules for Certain Financial Professionals” (Mar. 1, 2016). FinCEN Notice of proposed rulemaking, Amendment to the Bank Secrecy Act Regulations — Reports of Foreign Financial Accounts. The Financial Crimes Enforcement Network (FinCEN) has issued proposed regs that would clarify and revise certain rules relating to the filing of […]

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IRS corrects Notice announcing changes to withholding and FATCA regs

IRS corrects Notice announcing changes to withholding and FATCA regs

Notice 2016 – 08, Timing of Submitting Preexisting Accounts and Periodic Certifications; Reporting of Accounts of Nonparticipating FFIs; Reliance on Electronically Furnished Forms W – 8 and W – 9. To reduce a number of compliance burdens, IRS announced in Notice 2016-8 that it intended to amend several regs with respect to chapters 3 (withholding […]

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IRS will amend nonresident, etc. withholding and FATCA regs to reduce compliance burdens

IRS will amend nonresident, etc. withholding and FATCA regs to reduce compliance burdens

Notice 2016-8, 2016-6 IRB In a Notice, IRS has announced that it intends to amend several regs with respect to chapters 3 (withholding of tax on nonresident aliens and foreign corporations) and 4 (the Foreign Account Tax Compliance Act; FATCA) of the Code to reduce a number of compliance burdens. Prior to the issuance of […]

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U.S. House tax writer pushes 2016 tax reform on foreign earnings

U.S. House tax writer pushes 2016 tax reform on foreign earnings

WASHINGTON (Reuters) – The U.S. House of Representatives’ top tax writer wants a vote this year on legislation moving the United States to a territorial-style tax system aimed at exempting the earnings of American companies abroad from U.S. taxation. International tax reform should be tackled as the first step toward a bigger rewrite of the […]

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Draft 2015 FATCA Form 8966 instructions reflect form’s new check boxes and lines

Draft 2015 FATCA Form 8966 instructions reflect form’s new check boxes and lines

Draft 2015 Instructions for Form 8966. IRS has published a draft version of the instructions to the 2015 Form 8966 (FATCA Report), which certain foreign financial institutions (FFIs) and others use to report information with respect to U.S. accounts under the Foreign Account Tax Compliance Act (FATCA). The instructions reflect the fact that 2015 Form […]

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New final 2016 Form 1099-B provides for FATCA compliance, makes other changes

New final 2016 Form 1099-B provides for FATCA compliance, makes other changes

2016 Form 1099-B, Proceeds from Broker and Barter Exchange Transactions. IRS has issued the final version of 2016 Form 1099-B, Proceeds from Broker and Barter Exchange Transactions. Among the changes from the 2015 form is a new checkbox to be used if the form is being used to meet requirements of the Foreign Account Tax Compliance Act […]

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IRS issues FATCA updates and new guidance

IRS issues FATCA updates and new guidance

IRS has announced that it has released six new YouTube videos explaining upgrades to the Foreign Account Tax Compliance Act (FATCA) Online Registration System, upgraded the Foreign Financial Institution (FFI) List Search and Download Tool, and added new frequently asked questions (FAQs) about general FATCA compliance. It also announced the dates on which the International […]

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FATCA FAQ provides guidance on foreign partnership & trust agreements

FATCA FAQ provides guidance on foreign partnership & trust agreements

IRS has recently updated its list of frequently asked questions (FAQs) to provide information on the effective date of an entity’s withholding foreign partnership (WP) or withholding foreign trust (WT) agreement, if the entity submits an application for WP or WT status on or after April 1 and is approved for such status. Click here to view […]

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Competent Authority Arrangements facilitate U.S.-U.K & Australia FATCA data exchange

Competent Authority Arrangements facilitate U.S.-U.K & Australia FATCA data exchange

IR 2015-108 To facilitate the exchange of Foreign Account Tax Compliance Act (FATCA) data under the intergovernmental agreements (IGAs) with Australia and the U.K., the U.S. Competent Authority has signed Competent Authority Arrangements (CAAs) with the Competent Authority of each country, announced IRS officials on September 24. The CAAs are the first of such arrangements […]

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IRS adds 16 approved countries to list of countries with which it exchanges certain tax data

IRS adds 16 approved countries to list of countries with which it exchanges certain tax data

Rev Proc 2015-50, IRB 2015-42 In a Revenue Procedure, IRS has updated the list of countries with which Treasury and IRS have determined that it is appropriate to have an automatic exchange relationship under Reg. § 1.6049-8(a) and Reg. § 1.6049-4(b)(5), which require the reporting of certain deposit interest aggregating $10 or more paid to […]

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Newly signed CAAs facilitate FATCA data exchange between U.S.-U.K & Australia

Newly signed CAAs facilitate FATCA data exchange between U.S.-U.K & Australia

IR 2015-108 To facilitate the exchange of Foreign Account Tax Compliance Act (FATCA) data under the intergovernmental agreements (IGAs) with Australia and the U.K., the U.S. Competent Authority has signed Competent Authority Arrangements (CAAs) with the Competent Authority of each country, announced IRS officials on September 24. The CAAs are the first of such arrangements […]

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Senator and others denied preliminary injunctive relief from foreign account reporting regime

Senator and others denied preliminary injunctive relief from foreign account reporting regime

Crawford, et al, v. Dept. of Treasury, et al, (DC OH 09/29/2015) 116 AFTR 2d ¶2015-5294 A district court has declined to grant a preliminary injunction in a suit challenging the Foreign Accounting Tax Compliance Act (FATCA) and Foreign Bank Account Report (FBAR) requirements. The court’s reasoning included that the challengers (including Senator Rand Paul) […]

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IRS will amend FATCA regs to extend various transitional rules

Notice 2015-66, 2015-41 IRB In a Notice, IRS has announced that it will amend the Foreign Account Tax Compliance Act (FATCA) regs to extend the period of time that certain transitional rules will apply and to modify the rules for grandfathered obligations in relation to collateral held by withholding agents. The Notice also provides information […]

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IRS will amend FATCA regs to extend various transitional rules

Notice 2015-66, 2015-41 IRB In a Notice, IRS has announced that it will amend the Foreign Account Tax Compliance Act (FATCA) regs to extend the period of time that certain transitional rules will apply and to modify the rules for grandfathered obligations in relation to collateral held by withholding agents. The Notice also provides information […]

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Updated FATCA FAQs Clarify Branch and Disregarded Entity Registration Requirements

Updated FATCA FAQs Clarify Branch and Disregarded Entity Registration Requirements

IRS has recently updated its list of frequently asked questions (FAQs) to clarify branch and disregarded entity (DRE) registration requirements under the Foreign Account Tax Compliance Act (FATCA). In general, unless a specific exception applies, a branch must register as a branch of its owner, rather than as a separate entity. IRS also provides instructions […]

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Washington Alert – TIGTA faults ITIN procedures; Applications open for ACT; IRS Reference Guide updated on FBARs; US & Turkey sign FACTA agreement

Washington Alert – TIGTA faults ITIN procedures; Applications open for ACT; IRS Reference Guide updated on FBARs; US & Turkey sign FACTA agreement

A Treasury Inspector General for Tax Administration (TIGTA) audit released on Aug. 6 found that IRS’s Individual Taxpayer Identification Number (ITIN) application processes and procedures do not ensure that documents certified by a foreign issuing agency are authentic. (Audit Report No. 2015-40-038) An ITIN is issued to individuals who are required to have a Taxpayer […]

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IRS sheds light on when incoming and outgoing FATCA information becomes confidential

IRS sheds light on when incoming and outgoing FATCA information becomes confidential

Legal Advice Issued by Associate Chief Counsel 2015-005 In a redacted Legal Advice Issued by Associate Chief Counsel, IRS has given its opinion on the exact moment when information that it provides to, and information it receives from, foreign tax authorities and other parties pursuant to the Foreign Account Tax Compliance Act (FATCA), becomes protected […]

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Washington Alert – Rand Paul supports lawsuit to strike down FATCA;U.S. and the Philippines sign an IGA; IRS webinars on ACA

Washington Alert – Rand Paul supports lawsuit to strike down FATCA;U.S. and the Philippines sign an IGA; IRS webinars on ACA

Sen. Rand Paul (R-KY) on July 14 joined six other plaintiffs in filing a lawsuit in U.S. District Court for the Southern District of Ohio that, among other things, would strike down the Foreign Account Tax Compliance Act (FATCA)-related intergovernmental agreements (IGAs) the U.S. has signed with Canada, the Czech Republic, Israel and Switzerland. (Crawford […]

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Washington Alert – Tax Refund Fraud, DOJ and 2 more banks in Swiss Bank Program; US & Romania sign IGA; IRS Nationwide Tax Forums

Washington Alert – Tax Refund Fraud, DOJ and 2 more banks in Swiss Bank Program; US & Romania sign IGA; IRS Nationwide Tax Forums

Declaring the prevention of tax refund fraud “an area with room for vast improvement,” the bipartisan leadership of the Senate Finance Committee on June 4 called for enhanced cooperation between Capitol Hill, IRS, state agencies, law enforcement and the tax preparation industry. “It is clear that current measures to prevent tax fraud are insufficient and […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney