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You can run but can you still hide?

With the passage and implementation of the Foreign Account and Tax Compliance Act (FATCA), much has been made of the US government’s attempt to crack down on its citizens’ use of accounts in so called “Tax Haven” jurisdictions.  However, many foreign governments and tax commentators have noted that, in fact, the US is one of […]

The United States is now the new Switzerland

The recent trending article by Bloomberg, The World’s New Tax Haven is the United States, has the financial offshore community’s full attention. The Nevada LLC has been the choice entity for foreign investors for quite some time due to zero state tax exposure and minimal federal liabilities. So why the sudden urgency for foreign trusts to […]

The IRS extends FATCA’s Withholding Requirements

On September 18, 2015 the Department of Treasury and the IRS announced the intent to amend regulations relating to FATCA’s withholding rules to extend the following: The date for when withholding on gross proceeds and foreign passthru payments will begin The use of limited branches and limited foreign financial institutions (limited FFIs) The deadline for […]

UK Ltd Company: Opening a US Bank Account

Your UK Limited company has ventured out to the Wild West to do business and you quickly find a US bank account is required.  The idea of opening a US account seems alluring when you think of the potential business that 400 million consumers can bring. So you jump on the band wagon and file […]

Jersey to consider extension requests from FIs on FATCA reporting

The Treasury and Resources division of the Channel Island of Jersey has recently issued a notice to registered financial institutions offering a consideration of leniency on the approaching FATCA account reporting deadline: “… as this is the first reporting period for the Jersey-US FATCA Agreement, it is appreciated that a Reporting Financial Institution may have been […]

A small reprieve from FATCA

The IRS has given foreign financial institutions (FFIs), such as banks, additional time to update their reporting systems through an amendment to the temporary FATCA regulations.  The Department of Treasury and the Internal Revenue Service have stated, in IRS Notice 2014-59 that withholding agents and payers have an extended time of implementing their new entity account procedures from July 1, […]

FATCA: Foreign Funds Lending into the US and Investing in US Indebtedness Should Take Heed

The recent enactment of the Foreign Account Tax Compliance Act (“FATCA”) has greatly expanded the tax reporting obligations of foreign persons investing in the US. Ostensibly targeted by the drafters of this legislation, private equity funds and hedge funds investing in the US (through either debt or equity investments) should be particularly concerned with the […]

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