1. FBAR Filing Requirement The FBAR refers to Form 114, Report of Foreign Bank and Financial Accounts.  The FBAR must be filed annually by a U.S. person that has a financial interest in or signature authority over foreign financial accounts if the aggregate value of the foreign financial accounts exceeds $10,000 at any time during the…

GIIN Lists Analysis: June 2014 through April 2015 April’s global GIIN registrations, like March, were unimpressive.  Financial institution GIIN total registrations ticked up from an unimpressive 2,479 additional ones in March to 3,734 in April, bringing the ultimate GIIN count to 160,010 from the March result of 156,276.  The 112 IGA signatories, and IGA agreements…

After the first post on BEPS, I decided to go laterally and approach an issue that may resonate to many tax practitioners but unfortunately is not so widely discussed perhaps because of its interdisciplinary impacts – what are the consequences and limits for this “rush” towards massification of tax information data retrieval and exchange. We…

General Introduction From 1 July 2014, U.S. withholding agents have imposed, with very limited exceptions, the new Internal Revenue Code (IRC) Chapter 4 withholding (a.k.a. FATCA) of 30 percent on ‘withholdable’ payments to foreign financial institutions (FFIs) that do not appear on the IRS’ published GIIN list. However, U.S. Treasury delayed the imposition of the…