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Intergovernmental Agreements

Reminder: Mar. 31 is deadline for many inherited property basis returns

Reminder: Mar. 31 is deadline for many inherited property basis returns

The due date for filing returns with IRS and providing statements to beneficiaries under the rules requiring consistent basis reporting for inherited property for estate tax and income tax purposes, where the estate tax return of the decedent was filed after July 31, 2015, is Mar. 31, 2016, except with respect to decedents that died very […]

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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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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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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 – DHS investigates inverted corporations; IRS Whistleblower Office receives lots of attention; U.S. & Vietnam sign accord; U.S. & India sign IGA; JCT Report on Excise Taxes

Washington Alert – DHS investigates inverted corporations; IRS Whistleblower Office receives lots of attention; U.S. & Vietnam sign accord; U.S. & India sign IGA; JCT Report on Excise Taxes

A bicameral group of seven Democrats on July 9 called on the chief watchdog of the Department of Homeland Security (DHS) to investigate the possible violation of “multiple federal prohibitions on contracting with inverted corporations.” (Letter to John Roth, Office of Inspector General, Department of Homeland Security) The letter referred to a recent article which […]

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Washington Alert – Tax Season; US and Qatar sign IGA; JCT on expiring provisions

Washington Alert – Tax Season; US and Qatar sign IGA; JCT on expiring provisions

With an eye on the upcoming tax filing season, the Treasury Department and the Department of Health and Human Services are revving up to provide tax filers with information and resources they may need as a result of the Affordable Care Act (ACA), the two departments said in a Jan. 8 joint statement. Consumers can […]

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IRS issues long-awaited Instructions for FATCA form for entities, Form W-8BEN-E

IRS issues long-awaited Instructions for FATCA form for entities, Form W-8BEN-E

IRS has released the long-awaited Instructions to Form W-8BEN-E (June 2014), Certificate of Status of Beneficial Owner for United States Tax Withholding and Reporting (Entities). This form is used exclusively by entities to document their status both as a payee under chapter 4 and a beneficial owner under chapter 3 of the Code, and to […]

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IRS issues Instructions for Form 8966, FATCA Report

IRS issues Instructions for Form 8966, FATCA Report

IRS has released Instructions for Form 8966, FATCA Report, which is used to report information with respect to certain U.S. accounts, substantial U.S. owners of passive non-financial foreign entities (NFFEs), U.S. accounts held by owner-documented foreign financial institutions (FFIs), and certain other accounts based on the filer’s chapter 4 status. For calendar years 2015 and […]

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Final 2014 Form 1042 reflects major changes including new FATCA withholding

Final 2014 Form 1042 reflects major changes including new FATCA withholding

Click here for 2014 Form 1042, Annual Withholding Tax Return for U.S. Source Income of Foreign Persons. Click here for the Instructions for 2014 Form 1042, Annual Withholding Tax Return for U.S. Source Income of Foreign Persons. IRS has issued final 2014 Form 1042, Annual Withholding Tax Return for U.S. Source Income of Foreign Persons. […]

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IRS delays FATCA financial institution registration deadline & liberalizes IGA treatment

IRS delays FATCA financial institution registration deadline & liberalizes IGA treatment

In Ann. 2014-17, 2014-17 IRB, IRS has announced guidance to foreign financial institutions (FFIs) in jurisdictions that haven’t signed an intergovernmental agreement (IGA) to implement the Foreign Account Tax Compliance Act (FATCA) provisions, but that have reached an agreement in substance with the U.S. on the terms of such an IGA. The guidance also provides […]

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Canada to give bank account information to IRS under tax-sharing deal

Canada to give bank account information to IRS under tax-sharing deal

OTTAWA (Reuters) – Canada and the United States have signed a tax-information sharing agreement, officials from the two countries said on Wednesday, months ahead of implementation of a new U.S. law to crack down on offshore tax avoidance. The so-called intergovernmental agreement (IGA), one of 22 Washington has signed so far with individual countries, aims […]

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Practitioners discuss FATCA compliance issues amidst speculation about further delay

Practitioners discuss FATCA compliance issues amidst speculation about further delay

At a recent panel discussion on Foreign Account Tax Compliance Act (FATCA) developments sponsored by the New York State Society of CPAs in Manhattan, practitioners weighed in on a number of topics including compliance issues, rumors of a further delayed implementation, and the implications of FATCA for various entities. Background. On Mar. 18, 2010, the […]

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Canada to give bank account information to IRS under tax-sharing deal

Canada to give bank account information to IRS under tax-sharing deal

OTTAWA (Reuters) – Canada and the United States have signed a tax-information sharing agreement, officials from the two countries said on Wednesday, months ahead of implementation of a new U.S. law to crack down on offshore tax avoidance. The so-called intergovernmental agreement (IGA), one of 22 Washington has signed so far with individual countries, aims […]

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US Treasury signs anti-tax evasion pacts with six jurisdictions

US Treasury signs anti-tax evasion pacts with six jurisdictions

US Treasury signs anti-tax evasion pacts with six jurisdictions. WASHINGTON (Reuters) – The U.S. Treasury Department said on Thursday it has signed six more anti-tax evasion pacts with foreign governments, including several jurisdictions previously criticized as tax havens. The agreements were completed this past week with Bermuda, Malta, the Netherlands and three UK Crown Dependencies: […]

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Shutdown slows U.S. bilateral talks to fight offshore tax dodgers

Shutdown slows U.S. bilateral talks to fight offshore tax dodgers

As reported in Reuters, “Shutdown slows U.S. bilateral talks to fight offshore tax dodgers,” the federal government shutdown has interrupted U.S. efforts to negotiate agreements with other countries on implementing an anti-tax evasion law that is to take effect next year, tax lawyers said on Friday. The Foreign Account Tax Compliance Act (FATCA), enacted in […]

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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