…Means Subcommittee on Select Revenue Measures March 31, 2009, Accessed from https://www.ctj.org/pdf/mcintyresw&mtestimony20090331.pdf on 4th March 2020 [4] Ibid. [5] William Byrnes and Robert J. Munro, Background and Current Status of…
…as William Byrnes observed in his recent post, the differences accounted in dollars would not necessarily be significant. Moreover, in order to obtain such a favourable position, the tax authorities…
…November 177,147 December 178,870 January 2016 182,649 For further FATCA GIIN, CRS, and LEI analysis, see Perryman and Byrnes’ work in the Guide to FATCA Compliance . Origin Registrations (January…
…are excluded from the definition of financial account in the IGA are also not required to be reported on Form 8938. Professor Byrnes (Texas A&M Law) 2015 edition of the…
In a double take two-to-one decision because of a withdrawn decision due to the death of a judge, a Ninth Circuit panel in Altera reversed a unanimous en banc decision…
Our 14-page comments and recommendations of 14 tax professionals and academics from 11 countries raise additional issues and concerns, and propose additional recommendations to undertake a detailed cost benefit analysis…
GIIN Lists Analysis: June 2014 through March 2015 In the words of my English colleague Haydon Perryman, March was a “bit of a damp squib”. Financial institution FATCA registrations have…
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…
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…
This month I am going to present the first part (the justification) of a Congressional proposal that I am working upon for an academic article (I will appreciate any feedback)….
After a decade, the Treasury Department issued a new U.S. Model Income Tax Convention (the “2016 Model”), which is the baseline text the Treasury Department uses when it negotiates tax…
What do these two things have in common? Dr. Andrew P. Morriss, Dean & Anthony G. Buzbee Dean’s Endowed Chair, Texas A&M School of Law explains In 1998, seven US…
MNC profit shifting has received major attention over the past few years. Total earnings stockpiled overseas are now reported to be in excess of $2 trillion. One of the authors…
This month I will discuss the important topic for the anti-money laundering compliance officer, wherein the AML systems overlap with the requirement for tax compliance, and that tax compliance requirement…
