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Intergovernmental Agreements (IGAs)

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

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

Rev Proc 2016-18, 2016-16 IRB 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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31 countries sign international agreement on country-by-country reporting, but not U.S.

31 countries sign international agreement on country-by-country reporting, but not U.S.

OECD press release (Jan. 27, 2015). On January 27, finance ministers and top officials from 31 countries — which didn’t include the U.S. — signed the Multilateral Competent Authority Agreement on the Exchange of Country-by-Country Reports (the Agreement), according to an OECD press release. This is the first signing ceremony for the Agreement to facilitate […]

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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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Washington Alert – IRPAC report on TINs; e-file Providers must answer the annual self-certification questions; U.S. & San Marino sign IGA; revised Publication 4557, Safeguarding Taxpayer Data

Washington Alert – IRPAC report on TINs; e-file Providers must answer the annual self-certification questions; U.S. & San Marino sign IGA; revised Publication 4557, Safeguarding Taxpayer Data

Issues revolving around taxpayer identification numbers (TINs) are addressed in several recommendations appearing in the annual report of the Information Reporting Program Advisory Committee (IRPAC). (IR 2015-121) As stated in its report, the purpose of IRPAC “is to identify, and make specific recommendations for, areas of the information reporting program which can be improved by […]

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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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Washington Alert – Judge ok’s lawsuit against ACA; U.S. St.Kitts, Nevus sign IGA; Yahoo loses PLR; IRS announces ‘Penalties at a Glance’

Washington Alert – Judge ok’s lawsuit against ACA; U.S. St.Kitts, Nevus sign IGA; Yahoo loses PLR; IRS announces ‘Penalties at a Glance’

A federal judge in Washington, D.C. on Sept. 9, in a memorandum opinion, ruled that the House of Representatives has standing to pursue certain constitutional claims regarding the Obama administration’s actions to implement the Affordable Care Act (ACA). (Civil Action No. 14-1967) As outlined in the opinion of Judge Rosemary Collyer of the U.S. District […]

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Washington Alert – Health Insurance Companies and ACA; U.S. and St. Vincent and the Grenadines on Aug. 18 sign an intergovernmental agreement; TIGTA on levies and taxpayer rights

Washington Alert – Health Insurance Companies and ACA; U.S. and St. Vincent and the Grenadines on Aug. 18 sign an intergovernmental agreement; TIGTA on levies and taxpayer rights

IRS on Aug. 27 advised taxpayers that health insurance companies may ask policyholders to provide Social Security numbers (SSNs) for themselves, spouses and children covered by the policies. (HCTT-2015-53) “This is because the Affordable Care Act requires every provider of minimum essential coverage to report that coverage by filing an information return with the IRS […]

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Washington Alert – TIGTA Report on Appeals decisions on penalty abatement; US & Portugal sign IGA; Reminder – E-File Application

Washington Alert – TIGTA Report on Appeals decisions on penalty abatement; US & Portugal sign IGA; Reminder – E-File Application

The IRS Office of Appeals (Appeals), in many of the cases reviewed, correctly accepted cases in which agency operating divisions had previously denied the taxpayer’s request for abatement and provided sufficient documentation of the reasons for penalty abatements in case files, according to an audit released on Aug. 21 by the Treasury Inspector General for […]

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Washington Alert – TIGTA report on partnership audits; US and Kuwait sign IGA;Applications to serve on IRSAC; IRS and Small Business; 2016 LITC application process

Washington Alert – TIGTA report on partnership audits; US and Kuwait sign IGA;Applications to serve on IRSAC; IRS and Small Business; 2016 LITC application process

IRS has taken actions designed to improve the partnership audit process, but the agency remains unaware of the degree of partnership tax compliance, the Treasury Inspector General for Tax Administration (TIGTA) said in an audit released on April 28. (Audit Report No. 2015-30-004) As described in the audit, since partnerships are not taxed directly, the […]

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Deadline extended for FATCA IGAs that are not yet signed but are treated as in effect

Deadline extended for FATCA IGAs that are not yet signed but are treated as in effect

Ann. 2014-38, 2014-51 IRB In an Announcement, IRS has provided that a jurisdiction that is treated as if it had an intergovernmental agreement (IGA) in effect to implement the Foreign Account Tax Compliance Act (FATCA) provisions, but that has not yet signed an IGA, will retain that status beyond Dec. 31, 2014, if the jurisdiction […]

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Washington Alert – U.S. & Hong Kong Pact re FATCA; Credit Suisse Sentenced; TIGTA Report on “Missing” E-mails of IRS; Ryan is new Chair of House Ways & Means CommitteeSwitzerland on Nov. 19 signed the Multilateral Competent Authority Agreement

Washington Alert – U.S. & Hong Kong Pact re FATCA; Credit Suisse Sentenced; TIGTA Report on “Missing” E-mails of IRS; Ryan is new Chair of House Ways & Means CommitteeSwitzerland on Nov. 19 signed the Multilateral Competent Authority Agreement

The U.S. and the Hong Kong Special Administrative Region of the People’s Republic of China on Nov. 13 signed an agreement for cooperation to facilitate the implementation of the Foreign Account Tax Compliance Act (FATCA). On Nov. 17, the U.S. and Barbados signed an agreement to improve international tax compliance and to implement FATCA. The […]

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No more secrets – Swiss banks learn to shape up, not shut up

No more secrets – Swiss banks learn to shape up, not shut up

ZURICH (Reuters) – Switzerland’s allure as a place to stash cash has been badly damaged by a U.S.-led campaign against tax cheats, and the country’s roughly 140 private banks can no longer rely on a reputation for secrecy to attract wealthy customers. To try and compensate for the hundreds of billions of Swiss francs withdrawn […]

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Israel, U.S. sign tax information agreement

Israel, U.S. sign tax information agreement

TEL AVIV (Reuters) – Israel and the United States have signed an agreement aimed at improving international tax law enforcement and implementing the U.S. Foreign Accounts Tax Compliance Act (FATCA), Israel’s Finance Ministry said on Wednesday. The agreement regulates the transfer of information to the U.S. Internal Revenue Service (IRS) via the Israel Tax Authority, […]

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Washington Alert – IGA with Luxembourg, No reelection for Rep. Dave Camp, TIGTA Report on improper retirment funds issued, Update on IRS transcript requests

Washington Alert – IGA with Luxembourg, No reelection for Rep. Dave Camp, TIGTA Report on improper retirment funds issued, Update on IRS transcript requests

The U.S. and Luxembourg on March 28 signed an intergovernmental agreement (IGA) to implement the Foreign Account Tax Compliance Act (FATCA). As described by Luxembourg for Finance (LFF), a quasi-public agency, the IGA includes the automatic exchange of information between the tax authorities of both countries on assets held in Luxembourg by U.S. citizens and […]

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U.S. gives foreign banks more time on anti-tax dodge law

U.S. gives foreign banks more time on anti-tax dodge law

WASHINGTON (Reuters) – The U.S. Treasury Department on Wednesday gave foreign financial institutions 10 extra days to register with the U.S. government, under a new law to combat offshore tax dodging by Americans that goes into effect on July 1. Under the Foreign Account Tax Compliance Act (FATCA), foreign banks, insurers and investment funds must […]

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Cayman Islands, Costa Rica sign tax pacts with U.S

Cayman Islands, Costa Rica sign tax pacts with U.S

WASHINGTON (Reuters) – The United States has signed agreements with the Cayman Islands and Costa Rica to help those countries’ banks comply with an anti-tax evasion law starting next year, the Treasury Department said on Friday. The deals are part of the U.S. effort to enforce the Foreign Account Tax Compliance Act (FATCA), enacted in […]

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U.S. Treasury signs pact with France for anti-tax evasion law

U.S. Treasury signs pact with France for anti-tax evasion law

WASHINGTON (Reuters) – The United States has signed an anti-tax evasion agreement with France, the 10th country to join a U.S. global dragnet that goes into effect next July, the U.S. Treasury said on Thursday. The Foreign Account Tax Compliance Act (FATCA), enacted in 2010, will from then require financial institutions abroad to disclose Americans’ […]

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Bankers’ lawsuit jeopardizes U.S. tax dodger crackdown

Bankers’ lawsuit jeopardizes U.S. tax dodger crackdown

WASHINGTON/NEW YORK (Reuters) – A court challenge by Texas and Florida bankers threatens to undermine a broad U.S. government crackdown on offshore tax avoidance and jeopardize a web of carefully crafted international agreements, tax lawyers said recently. The Texas Bankers Association and the Florida Bankers Association, both industry groups, have filed a lawsuit attempting to […]

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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