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International - Treaties

The Supreme Court, Federal Taxation and the Constitution

April 29, 2013 By Jasper L. (Jack) Cummings, Jr. and Edward Tanenbaum

In my recently published book, The Supreme Court, Federal Taxation and the Constitution, I review several constitutional issues that could impact the coming consideration of broad scale tax reform in Congress. It is likely that Congress will be more attentive to possible constitutional issues than it was when it enacted the health care tax provisions in 2010. The failure to clearly label that tax as a tax fueled multiple lawsuits against the tax that ultimately had to be decided by the Supreme Court in a surprising split decision in which Chief Justice Roberts wound up siding with the supporters [...]Read more

Filed Under: Federal - Corporate Tax Planning, Federal Tax Litigation, International - Outbound, International - Treaties

International Update: FATCA, FBAR, Voluntary Disclosure

June 8, 2011 By Jasper L. (Jack) Cummings, Jr. and Edward Tanenbaum

To provide guidance to those subject to FATCA, the IRS issued Notice 2010-60 on August 27, 2010 (the “2010 Notice”), and Notice 2011-34 on April 8, 2011 (the “2011 Notice”).  The 2010 Notice provided general information about FATCA and the 2011 Notice provided more detailed guidance, including information on the concepts of “pass-thru payments” and “deemed-compliant FFIs.”  In recent weeks, IRS officials have attended various meetings of tax professionals to provide more insight about FATCA and to defend the new withholding regime as an [...]Read more

Filed Under: International - Inbound, International - Outbound, International - Treaties, Penalties Tagged With: FATCA

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