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FATCA

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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Washington Alert – PTIN expiration notices sent; GAO faults IRS phone service; Return preparers and EITC warning; FINCEN and insurance companies

Washington Alert – PTIN expiration notices sent; GAO faults IRS phone service; Return preparers and EITC warning; FINCEN and insurance companies

IRS announced on Jan. 22 that the Return Preparer Office has started mailing Preparer Tax Identification Number (PTIN) expiration notices to tax preparers who have not renewed their PTIN for 2016. (e-News for Tax Professionals 2016-3) According to the agency, some 150,000 such notices will be sent. The notice informs recipients that their PTIN can […]

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Streamlined offshore account compliance guidance for Canadian retirement plan participants

Streamlined offshore account compliance guidance for Canadian retirement plan participants

IRS has added new FAQs to its website on the IRS streamlined offshore account compliance program, that include guidance to participants in Canadian retirement plans.  Click here for the Streamlined Filing Compliance Procedures for U.S. Taxpayers Residing in the United States Frequently Asked Questions and Answers (Updated Jan. 7, 2016) (“Domestic Q&As”).  Click here for […]

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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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Washington Alert – JCT on List of Expiring Federal Tax Provisions; FATCA ‘Feel Good’ Survey; 2015 Filing Season; CBO on Revenue in 2015 – an infographic

Washington Alert – JCT on List of Expiring Federal Tax Provisions; FATCA ‘Feel Good’ Survey; 2015 Filing Season; CBO on Revenue in 2015 – an infographic

The Joint Committee on Taxation (JCT) on Jan. 8 published a document titled “List of Expiring Federal Tax Provisions 2016-2025.” (JCX-1-16) As described by JCT, the document provides a listing of federal tax provisions (other than those providing time-limited transition relief after the repeal of an underlying rule) that are currently scheduled to expire in […]

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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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IRS upgrades FATCA Online Registration System

IRS upgrades FATCA Online Registration System

IR 2015-131 IRS has upgraded the Foreign Account Tax Compliance Act (FATCA) Online Registration System to, among other things, enable sponsoring entities to register their sponsored entities to obtain a global intermediary identification number (GIIN). Background. on FATCA. The Hiring Incentives to Restore Employment Act of 2010 (P.L. 111-147) added chapter 4 (Code Sec. 1471 […]

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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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IRS releases draft of 2015 Form 8966 (FATCA Report)

IRS releases draft of 2015 Form 8966 (FATCA Report)

IRS has released a draft version of the 2015 Form 8966 (FATCA Report). The form is used by certain foreign financial institutions (FFIs) and others to report information with respect to U.S. accounts under the Foreign Account Tax Compliance Act (FATCA).  Click here to view draft 2015 Form 8966, FATCA Report (Oct. 6, 2015) Background […]

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Washington Alert – TIGTA report on FATCA; IRS pub on Safeguarding Taxpayer Data; TIGTA report on IRS failure to revoke the PTINs for unsuitable tax return preparers

Washington Alert – TIGTA report on FATCA; IRS pub on Safeguarding Taxpayer Data; TIGTA report on IRS failure to revoke the PTINs for unsuitable tax return preparers

IRS has made good progress in implementing the Foreign Account Tax Compliance Act (FATCA), the Treasury Inspector General for Tax Administration (TIGTA) said in an audit released on Oct. 13. (Audit Report No. 2015-30-085) As described in the audit, under FATCA, individual taxpayers with specified foreign financial assets that meet a certain dollar threshold are […]

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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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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 – GAO report on IRS Collection; Webinar on Independent Contractors; US and Slovak Republic sign IGA; Tax Policy paper on the Cadillac tax

Washington Alert – GAO report on IRS Collection; Webinar on Independent Contractors; US and Slovak Republic sign IGA; Tax Policy paper on the Cadillac tax

A recent report by the Government Accountability Office (GAO) focused on IRS’s collection process and found it heavily relies on the use of automation to categorize and route unpaid tax or unfiled tax return cases for potential selection. (GAO-15-647) The agency’s automated Inventory Delivery System (IDS) is used to categorize and route cases based on […]

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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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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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