This advisory discusses the U.S., Australian and UK tax authorities’ plan to share tax information regarding numerous trusts and other entities holding assets on behalf of residents throughout the world. The three countries have obtained a substantial amount of data, including information about the identities of individual owners and the advisors who helped them establish the structures. The announcement comes amid a flurry of anti-evasion activity spawned in large part by the Foreign Account Tax Compliance Act (FATCA).
The advisory also discusses how the IRS Offshore Voluntary Disclosure Program is not a guaranteed pass for taxpayers; relatedly, it also discusses how the practice of “quiet disclosures” continues.
The advisory is provided in PDF on the Alston & Bird website: www.alston.com/advisories/international-tax-5-15
Written by Edward Tanenbaum, Partner, Federal & International Tax | Alston & Bird LLP