Foreign Account Tax Compliance Act ("FATCA")

During July 2012, the United States Treasury Department released both reciprocal and non-reciprocal versions of model intergovernmental agreements for implementing the Foreign Account Tax Compliance Act (“FATCA”) with other countries.  These model agreements were developed in consultation with the United Kingdom, Spain, Italy, France and Germany. In a classic example of the old adage “America sneezes and the world catches a cold,” the International Development Committee of the United Kingdom’s...
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Report of Foreign Bank and Financial Accounts ("FBAR")

Based upon two recent examples, it is clear that the Internal Revenue Service (“IRS”) has not enacted a kinder and gentler approach to those taxpayers who do not timely file a Form TD F 90-22.1, entitled Report of Foreign Bank and Financial Accounts (“FBAR”) with respect to each and every bank account located in a foreign jurisdiction.  On July 24, 2012, a Florida resident and former UBS client was sentenced...
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Seminars & Events:

April, 2017 - CELESQ
“An Asset Protection Planning Primer for Estate Planning, Tax and Creditors Rights Lawyers”
Live Web Cast
May 31 – June 1, 2017 - 

SOUTHPAC TRUST OFFSHORE PLANNING INSTITUTE CONFERENCE 2017, “Asset Protection in a Changing World” (31 May 2017) and “Questions & Answer Panel on Industry Challenges to Asset Protection Structures” (1 June 2017)
Las Vegas, Nevada


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Contact Information

Barry S. Engel