Friday, December 18, 2015
Thursday, December 17, 2015
Wednesday, December 16, 2015
Tuesday, December 15, 2015
Monday, December 14, 2015
Friday, December 11, 2015
Thursday, December 10, 2015
Wednesday, December 9, 2015
Tuesday, December 8, 2015
Friday, December 4, 2015
Thursday, December 3, 2015
Tuesday, December 1, 2015
Monday, November 30, 2015
Monday, November 16, 2015
Friday, November 13, 2015
Thursday, November 12, 2015
Wednesday, November 11, 2015
Tuesday, November 10, 2015
Saturday, November 7, 2015
Sunday, November 1, 2015
Saturday, October 31, 2015
Friday, October 30, 2015
Thursday, October 29, 2015
Thursday, October 22, 2015
New Lexis Advance® Tax Platform Now Available to Law School Faculty & Students; Cutting-Edge International Tax Titles
On June 1, LexisNexis launched its new online tax research platform called Lexis Advance® Tax.
Already available to America’s law school faculty and students, it includes a rich, comprehensive package of nearly 1,400 sources, including tax news, primary law, journals and nearly 300 treatises, practice guides and forms products for both tax and estates lawyers.
Along with news, another strong area for L.A. Tax is its subpage devoted to International Tax. There, users will find a selection
of titles examining hot, cutting-edge issues like: Lexis Guide to FATCA Compliance, the Lexis global guide to anti-money laundering laws around the world, and the recently-revised Foreign Tax & Trade Briefs, 2nd Ed, which provides summaries of each country’s tax system and laws.
of titles examining hot, cutting-edge issues like: Lexis Guide to FATCA Compliance, the Lexis global guide to anti-money laundering laws around the world, and the recently-revised Foreign Tax & Trade Briefs, 2nd Ed, which provides summaries of each country’s tax system and laws.
All of these titles are produced by a team of tax experts led by Professor William H. Byrnes, Associate Dean, International Financial Law, at Texas A&M University Law School, in Fort Worth, the newest law school in Texas. See https://law.tamu.edu/
Looking for Lexis Advance Tax?
Sign in to www.lexisadvance.com, look for the pull-down menu called “Lexis Advance Research” in the upper-left corner. Click the down arrow and select Lexis Advance Tax.
Looking for Lexis Advance Tax?
Sign in to www.lexisadvance.com, look for the pull-down menu called “Lexis Advance Research” in the upper-left corner. Click the down arrow and select Lexis Advance Tax.
If you have questions or would like to schedule a short training, please contact your LexisNexis® Account Executive.
Wednesday, October 21, 2015
Tuesday, October 20, 2015
Friday, October 16, 2015
Wednesday, October 14, 2015
Tuesday, October 13, 2015
Monday, October 12, 2015
Thursday, October 8, 2015
Wednesday, October 7, 2015
Tuesday, October 6, 2015
Friday, October 2, 2015
Wednesday, September 30, 2015
Friday, September 25, 2015
Thursday, September 24, 2015
Wednesday, September 23, 2015
Tuesday, September 22, 2015
Friday, September 18, 2015
Friday, September 11, 2015
Thursday, September 10, 2015
Thursday, August 27, 2015
Tuesday, August 25, 2015
Monday, August 24, 2015
Friday, August 21, 2015
Tuesday, August 18, 2015
Friday, August 14, 2015
Thursday, August 13, 2015
Wednesday, August 12, 2015
Friday, August 7, 2015
Thursday, August 6, 2015
Wednesday, August 5, 2015
Tuesday, August 4, 2015
Monday, August 3, 2015
Friday, July 31, 2015
Vote on Best 100 Law Blogs for ABA
--- Vote for My Blog Please for 100 Best Annual Law Blogs ---
The American Bar Association (ABA) is creating its annual list of the 100 best legal blogs, and wants your vote on which blogs it should include.
Go to >http://www.abajournal.com/blawgs/blawg100_submit/ < to tell us about the International Financial Law Professor blog -[lawprofessors.typepad.com/intfinlaw]
The ABA may include some of the best comments in our Blawg 100 coverage. But keep the remarks pithy— a 500-character remarks limit.
Friend-of-the-blawg briefs are due no later than 11:59 p.m. CT on Friday, Aug. 16, 2015.
Much obliged for your continued support and readership - Prof. William Byrnes (Texas A&M Law)
The American Bar Association (ABA) is creating its annual list of the 100 best legal blogs, and wants your vote on which blogs it should include.
Go to >http://www.abajournal.com/blawgs/blawg100_submit/ < to tell us about the International Financial Law Professor blog -[lawprofessors.typepad.com/intfinlaw]
The ABA may include some of the best comments in our Blawg 100 coverage. But keep the remarks pithy— a 500-character remarks limit.
Friend-of-the-blawg briefs are due no later than 11:59 p.m. CT on Friday, Aug. 16, 2015.
Much obliged for your continued support and readership - Prof. William Byrnes (Texas A&M Law)
Thursday, July 30, 2015
Tuesday, July 28, 2015
Monday, July 27, 2015
Friday, July 24, 2015
Thursday, July 23, 2015
Wednesday, July 22, 2015
Tuesday, July 21, 2015
UK Amnesty Not Leading to Disclosure of Tax Evasion in Channels. Is It "Much To Do About Nothing"
http://lawprofessors.typepad.com/intfinlaw/2015/07/uk-amnesty-not-leading-to-disclosure-of-tax-evasion-in-channels-is-it-much-to-do-about-nothing-or-ar.html
Monday, July 20, 2015
Friday, July 17, 2015
Thursday, July 16, 2015
Wednesday, July 15, 2015
Monday, July 13, 2015
Friday, July 10, 2015
Wednesday, July 8, 2015
Friday, July 3, 2015
Swiss Privatbank Von Graffenried Admits Assisting US Clients Evade Tax, But Pays Smallest Penalty Yet
http://lawprofessors.typepad.com/intfinlaw/2015/07/swiss-privatbank-von-graffenried-admits-assisting-us-clients-evade-tax-but-pays-smallest-penalty-yet.html
Thursday, July 2, 2015
US Confiscates and Repatriates Art Works Associated With Brazil's Banco Santo 2004 Fraud and Money Laundering
http://lawprofessors.typepad.com/intfinlaw/2015/07/us-confiscates-and-repatriates-art-works-associated-with-brazils-banco-santo-2004-fraud-and-money-la.html
Wednesday, July 1, 2015
Tuesday, June 30, 2015
JP Morgan $2 billion suit against employees who joined Morgan Stanley.
http://lawprofessors.typepad.com/intfinlaw/2015/06/jpmorgan-sues-2b-team-who-left-for-morgan-stanley.html
Monday, June 29, 2015
Greek bank run, closed until July 6, economic collapse, Euro withdrawal next?
http://lawprofessors.typepad.com/intfinlaw/2015/06/greek-banks-closed-for-week-deposits-unavailable-euro-exit.html
Friday, June 26, 2015
Thursday, June 25, 2015
Tuesday, June 23, 2015
Monday, June 22, 2015
Wednesday, June 17, 2015
U.S. Persons Foreign Assets and Entities Reporting for the FATCA, FBAR and BE-10 Forms Due in June (Part II)
http://www.kluwertaxlawblog.com/blog/2015/06/17/u-s-persons-foreign-assets-and-entities-reporting-for-the-fatca-fbar-and-be-10-forms-due-in-june-part-ii/
Monday, June 15, 2015
Thursday, June 4, 2015
Wednesday, June 3, 2015
Monday, June 1, 2015
Wednesday, May 27, 2015
Tuesday, May 26, 2015
Monday, May 18, 2015
Saturday, May 16, 2015
Distance Education programs director career
http://lawprofessors.typepad.com/intfinlaw/2015/05/texas-am-seeking-associate-director-for-distance-education-programs.html
Tuesday, May 12, 2015
FinCEN releases new FBAR filing procedure !!!
http://lawprofessors.typepad.com/intfinlaw/2015/05/fincen-provides-additional-e-filing-method-for-fbar-individual-filers.html
Monday, May 11, 2015
FATCA lectures in Spain
http://lawprofessors.typepad.com/intfinlaw/2015/05/thank-you-madrid-hello-athens.html
Saturday, May 9, 2015
San Diego County Lawyer Sentenced to 12 Years in Prison for Defrauding Thousands of Distressed Homeowners in Loan Modification Scheme
http://lawprofessors.typepad.com/intfinlaw/2015/05/san-diego-county-lawyer-sentenced-to-12-years-in-prison-for-defrauding-thousands-of-distressed-homeo.html
Thursday, May 7, 2015
Criminal Charges Against Securities Market Spoofing
http://lawprofessors.typepad.com/intfinlaw/2015/05/criminal-charges-against-securities-market-spoofing.html?utm_source=feedburner&utm_medium=email&utm_campaign=Feed%3A+IntFinLaw+%28International+Financial+Law+Blog%29
Wednesday, May 6, 2015
Annuitizing the Inheritance: Tips and Tricks to Get It Right
http://lawprofessors.typepad.com/intfinlaw/2015/05/annuitizing-the-inheritance-tips-and-tricks-to-get-it-right.html
Monday, May 4, 2015
Friday, May 1, 2015
Thursday, April 30, 2015
Fiscalidad Internacional: las obligaciones FATCA - 8 Mayo (Viernes) en Madrid
Fecha: Viernes 8 de mayo a las 19.00 horas Date: Friday, May 8th at 19:00
Lugar:
CEF.- Paseo General Martínez Campos, 5, Madrid
Ponentes:
Professor William H. Byrnes (Texas A&M University School of Law)
RSVP Required: http://acef.cef.es/FATCA
Programa:
La norma era necesaria para financiar una ley de empleo, que incluía beneficios para afrontar el desempleo, problema que surgió como consecuencia de esa crisis financiera. Sin embargo, las cifras actuales de recaudo tributario adicional que se han producido después de la ley están entre 300 y 500 millones de dólares por año. Parece mucho dinero, pero, en realidad, solo es el 0,003 % de la previsión de 150 billones de dólares.
Además, la Ley FATCA va a significar el aumento del recaudo en un solo momento, porque si se tienen 100.000 evasores, cuando estos se vuelvan cumplidores de la ley tributaria, a raíz de la Fatca, se va a registrar un aumento del recaudo, pero no de ahí en adelante con relación a esas mismas personas. Estadísticamente, es un hecho que no hay muchos contribuyentes estadounidenses que estén evadiendo tributos mediante otros países. El número de evasores, aunque uno nunca puede estar totalmente seguro, está entre 100.000 y 150.000. Pero es más probable que sean 100.000. Sin embargo, solamente en el 2014, se entregaron 150 millones de declaraciones tributarias en EE UU por parte de individuos. O sea que no estamos hablando, ni siquiera, del 1%.
La evasión fiscal es mala, aunque también lo es el homicidio y nunca vamos a poder evitar todos los homicidios, ni toda la evasión tributaria. De manera que la pregunta de política pública que se debe formular es, desde la perspectiva del contribuyente, ¿cómo vamos a utilizar los recursos limitados para atacar o limitar al máximo la evasión tributaria? La peor forma de lograr el cumplimiento tributario y de la ley, en general, es la amenaza con la sanción. No se puede eliminar la sanción de la ley, pero la mejor forma de promover su cumplimiento es mediante incentivos acordes con lo que la sociedad acepta.
- Summary of FATCA Obligations
- Determine Status of Foreign Entity
- Withholdable Payments
- Documentation and Due Diligence
- Withholding
- Reporting
- IGA Update and Global Information Exchange
La norma era necesaria para financiar una ley de empleo, que incluía beneficios para afrontar el desempleo, problema que surgió como consecuencia de esa crisis financiera. Sin embargo, las cifras actuales de recaudo tributario adicional que se han producido después de la ley están entre 300 y 500 millones de dólares por año. Parece mucho dinero, pero, en realidad, solo es el 0,003 % de la previsión de 150 billones de dólares.
Además, la Ley FATCA va a significar el aumento del recaudo en un solo momento, porque si se tienen 100.000 evasores, cuando estos se vuelvan cumplidores de la ley tributaria, a raíz de la Fatca, se va a registrar un aumento del recaudo, pero no de ahí en adelante con relación a esas mismas personas. Estadísticamente, es un hecho que no hay muchos contribuyentes estadounidenses que estén evadiendo tributos mediante otros países. El número de evasores, aunque uno nunca puede estar totalmente seguro, está entre 100.000 y 150.000. Pero es más probable que sean 100.000. Sin embargo, solamente en el 2014, se entregaron 150 millones de declaraciones tributarias en EE UU por parte de individuos. O sea que no estamos hablando, ni siquiera, del 1%.
La evasión fiscal es mala, aunque también lo es el homicidio y nunca vamos a poder evitar todos los homicidios, ni toda la evasión tributaria. De manera que la pregunta de política pública que se debe formular es, desde la perspectiva del contribuyente, ¿cómo vamos a utilizar los recursos limitados para atacar o limitar al máximo la evasión tributaria? La peor forma de lograr el cumplimiento tributario y de la ley, en general, es la amenaza con la sanción. No se puede eliminar la sanción de la ley, pero la mejor forma de promover su cumplimiento es mediante incentivos acordes con lo que la sociedad acepta.
Tuesday, April 28, 2015
Monday, April 27, 2015
Friday, April 24, 2015
Taxpayer Advocate Recommendations Changing FBAR Penalties, One Reporting Form
International Financial Law Prof Blog
A U.S. citizen or resident with foreign accounts exceeding $10,000 can be subject to disproportionate civil penalties for failure to report the accounts on a Report of Foreign Bank and Financial Accounts (or FBAR) by June 30 of the following year. Another penalty may apply if the accounts exceed $50,000 and the person does not report them on Form 8938, Statement of Specified Foreign Financial Assets, which is part of the tax return.
read about the proposed reforms at International Financial Law Prof Blog
A U.S. citizen or resident with foreign accounts exceeding $10,000 can be subject to disproportionate civil penalties for failure to report the accounts on a Report of Foreign Bank and Financial Accounts (or FBAR) by June 30 of the following year. Another penalty may apply if the accounts exceed $50,000 and the person does not report them on Form 8938, Statement of Specified Foreign Financial Assets, which is part of the tax return.
read about the proposed reforms at International Financial Law Prof Blog
Christian Bittar, One of Deutsche Bank's LIBOR Manipulators, Earned $136 million bonus just in 20
full story at International Financial Law Prof Blog
Deutsche Bank Employee: This "is a corrupt fixing and DB is part of it!"
Deutsche Bank Employee Seeking to Obtain Lower Rate: "I’m begging u, don’t forget me… pleassssssssssssssseeeeeeeeee… I’m on my knees…"
read on at International Financial Law Prof Blog
Thursday, April 23, 2015
Deutsche Bank's Pleads Guilty, Pay $2.519 billion in Penalties & Disgorgement, for Manipulating LIBOR
International Financial Law Prof Blog
Together with approximately $1.744 billion in regulatory penalties and disgorgement—$800 million as a result of a Commodity Futures Trading Commission (CFTC) action, $600 million as a result of a New York Department of Financial Services (DFS) action, and $344 million as a result of a U.K. Financial Conduct Authority (FCA) action—the Justice Department’s criminal penalties bring the total amount of penalties to approximately $2.519 billion.
Together with approximately $1.744 billion in regulatory penalties and disgorgement—$800 million as a result of a Commodity Futures Trading Commission (CFTC) action, $600 million as a result of a New York Department of Financial Services (DFS) action, and $344 million as a result of a U.K. Financial Conduct Authority (FCA) action—the Justice Department’s criminal penalties bring the total amount of penalties to approximately $2.519 billion.
Wednesday, April 22, 2015
Tuesday, April 21, 2015
Monday, April 20, 2015
Wednesday, April 15, 2015
Former New York Assemly Speaker Sheldon Silver's Headaches Mount as Son-in-Law Indicted in Ponzi Scheme
http://lawprofessors.typepad.com/intfinlaw/2015/04/former-new-york-assemly-speaker-sheldon-silvers-headaches-mount-as-son-in-law-indicted-in-ponzi-sche.html
Lehman Brothers case study of strong then weak risk management. Why did its risk management protocols change?
http://lawprofessors.typepad.com/intfinlaw/2015/04/the-lehman-brothers-bankruptcy-b-risk-limits-and-stress-tests.html
Monday, April 13, 2015
Texas A&M hires 9 new law professors, expands to 48 faculty
http://lawprofessors.typepad.com/intfinlaw/2015/04/texas-am-hires-nine-highly-published-law-faculty.html
Saturday, April 11, 2015
HSBC criminally charged by France
http://lawprofessors.typepad.com/intfinlaw/2015/04/hsbc-faces-french-criminal-tax-probe.html
Friday, April 10, 2015
What Hapens When Greece Defaults its May $823 million tranche?
http://lawprofessors.typepad.com/intfinlaw/2015/04/greece-repays-imf-aprils-485-million-but-where-will-mays-823-million-come-from.html
Bitcoin regulatory survey
http://lawprofessors.typepad.com/intfinlaw/2015/04/the-block-is-hot-a-survey-of-the-state-of-bitcoin-regulation-and-suggestions-for-the-future.html
Wednesday, April 8, 2015
Tuesday, April 7, 2015
Monday, April 6, 2015
Taxing Previously Untaxed Foreign Income (Guest Blogger Jeffery M. Kadet)
In connection with any transition to a new international tax system, we need an approach that effectively deals with the trillions of dollars of previously untaxed foreign income held by CFCs. There is logic and fairness in applying a rate on those earnings that is less than the 35 percent home country rate because the rules of the game are being changed significantly. read the full analysis of 35 year international tax veteran Jeffery Kadet at International Financial Law Prof Blog
#jefferykadet #CFC #BEPS #OECD
#jefferykadet #CFC #BEPS #OECD
Saturday, April 4, 2015
Friday, April 3, 2015
Thursday, April 2, 2015
Wednesday, April 1, 2015
Tuesday, March 31, 2015
First Bank To Be Resolved Under DOJ's Swiss Bank Non Prosecution Agreement Program
International Financial Law Prof Blog
The Department of Justice announced that BSI SA, one of the 10 largest private banks in Switzerland, is the first bank to reach a resolution under the Department of Justice’s Swiss Bank Program. 106 Swiss banks have sought non-prosecution agreements.
read the details at International Financial Law Prof Blog
The Department of Justice announced that BSI SA, one of the 10 largest private banks in Switzerland, is the first bank to reach a resolution under the Department of Justice’s Swiss Bank Program. 106 Swiss banks have sought non-prosecution agreements.
read the details at International Financial Law Prof Blog
Tuesday, March 24, 2015
Friday, March 20, 2015
Thursday, March 19, 2015
Other EU Tax Transparency Measures
Expanding the automatic exchange of information on financial accounts: In December 2014, Member States adopted landmark transparency measures through a revision to the Administrative Cooperation Directive. This requires Member States to automatically exchange information on the full spectrum of financial information from 2017, and spells the end of bank secrecy in the Single Market. The revised Directive, and other EU tax transparency measures, can be read at International Financial Law Prof Blog
Analysis of the EU's Tax Disclosure Directive
... oblige Member States to automatically exchange information on their tax rulings. This means that tax authorities would have to share a pre-defined set of information on all of their advance cross-border tax rulings with all other Member States. They would do this on a quarterly basis and following a standard format. Recipient Member States would then be allowed to request more detailed information on a particular tax ruling if they believe that it is relevant to their own taxation rules.
read the point by point analysis at International Financial Law Prof Blog
Wednesday, March 18, 2015
Former Managing Director of RBS Securities Admits To Multimillion Dollar Securities Fraud of RBS Customers
International Financial Law Prof Blog
Katke was a registered broker-dealer and managing director at RBS Securities Inc. Katke admitted that he and others conspired to increase RBS’s profits on CLO bond trades at the expense of customers. As part of the scheme, Katke and his co-conspirators made misrepresentations to induce buying customers to pay inflated prices and selling customers to accept deflated prices for CLO bonds, all to benefit RBS. read on at International Financial Law Prof Blog
Katke was a registered broker-dealer and managing director at RBS Securities Inc. Katke admitted that he and others conspired to increase RBS’s profits on CLO bond trades at the expense of customers. As part of the scheme, Katke and his co-conspirators made misrepresentations to induce buying customers to pay inflated prices and selling customers to accept deflated prices for CLO bonds, all to benefit RBS. read on at International Financial Law Prof Blog
Banca Privada d’Andorra Money Laundering Billions for Corruption and Human Traffickers?
....for several years, high–level managers at BPA have knowingly facilitated transactions on behalf of third–party money launderers acting on behalf of transnational criminal organizations ... read on at International Financial Law Prof Blog
Tuesday, March 17, 2015
OECD Releases 9 Country Evaluations On Implementation of Exchange of Tax Information To Combat Tax Evasion
International Financial Law Prof Blog
The Global Forum on Transparency and Exchange of Information for Tax Purposes published today 9 new peer review reports, including a Phase 1 Supplementary Report for Switzerland, demonstrating continuing progress toward implementation of the international standard for exchange of information on request.
The Global Forum on Transparency and Exchange of Information for Tax Purposes published today 9 new peer review reports, including a Phase 1 Supplementary Report for Switzerland, demonstrating continuing progress toward implementation of the international standard for exchange of information on request.
Commerzbank Admits to Sanctions and Money Laundering Violations, Will Pay $1.45 Billion Penalties!
International Financial Law Prof Blog
"If for whatever reason CB New York inquires why our turnover has increase[d] so dramatically, under no circumstances may anyone mention that there is a connection to the clearing of Iranian banks!!!!!!!!!!!!!.”
“we currently have 90 alerts a day,” with “808 alerts outstanding,” ...
read the full story at International Financial Law Prof Blog
"If for whatever reason CB New York inquires why our turnover has increase[d] so dramatically, under no circumstances may anyone mention that there is a connection to the clearing of Iranian banks!!!!!!!!!!!!!.”
“we currently have 90 alerts a day,” with “808 alerts outstanding,” ...
read the full story at International Financial Law Prof Blog
Sunday, March 8, 2015
Top Ten Identity Theft Prosecutions by IRS
“Identity theft is a crime that carries significant consequences, and these cases send a warning to criminals,” said Richard Weber, Chief, IRS-Criminal Investigation. “Our top 10 cases represent the seriousness of these crimes and the magnitude of the consequences that will be faced by those who victimize honest taxpayers and steal from hard-working Americans.”
Top Ten Identity Theft Cases - discover them at International Financial Law Prof Blog
The TIGTA Review of the Fiscal Year 2016 Funding Request for the IRS
International Financial Law Prof Blog
The Treasury Inspector General for Tax Administration, also known as “TIGTA,” is statutorily mandated to provide independent audit and investigative services necessary to improve the economy, efficiency, and effectiveness of the IRS, including the IRS Chief Counsel and the IRS Oversight Board.
discover the budget requests at International Financial Law Prof Blog
discover the budget requests at International Financial Law Prof Blog
Friday, March 6, 2015
FCA imposes £2.1m fine on Bank of Beirut and 2 employees for AML violations
The Bank of Beirut (UK) Ltd (Bank of Beirut) has been fined £2.1m by the Financial Conduct Authority (FCA) and stopped from acquiring new customers from high-risk jurisdictions for 126 days. In addition, the FCA has fined two approved persons at the bank. read why at International Financial Law Prof Blog
Wednesday, March 4, 2015
Distance Learning for Legal Education March 12-14 (Thursday - Saturday) at San Fran
Register without delay (and without cost) for the Distance Learning for Legal Education workgroup next week (March 12-14, Thursday - Saturday) in exciting San Fran.
Why should a Dean approve a travel budget for this workgroup? The American Bar Association initially acquiesced to an online LL.M. in 1998. Yet, it is since the initial inception of the Work Group in 2010 that most of the 47 LL.M.s offered online by 29 ABA full approved law schools have been founded. As of 2015, a majority of ABA law schools offer the opportunity for an online academic experience for J.D. students. One ABA law school has received a variance to offer a hybrid, partially residential / partially online, JD.
Who attends? Deans, Administrators, and Faculty from at least 83 ABA law schools and other stakeholders, such as foreign and U.S. academic institutions, publishers, and technology companies, have attended. Normally between 50 - 75 per workshop, and 100 for the AALS breakfasts.
What is the deliverable for a Dean? Guaranteed, collaborative engagement in discussions, writing, and editing that create the attached Work Group's recommendations. These best practice recommendations have been designed to adoptable by institutions and stakeholders through their adaptability and will form a component of a Distance Education policy. Everyone becomes a contributor, hence the name "work group". Attendees become the leader of the distance education pedagogical and policy discussions at home institutions.
Wednesday, February 25, 2015
Byrnes and Perryman’s Analysis of the FATCA GIIN Lists June 2014 – February 2015 | Kluwer International Tax Blog
Byrnes and Perryman’s Analysis of the FATCA GIIN Lists June 2014 – February 2015 | Kluwer International Tax Blog
Since the publication of the U.S. Treasury’s original GIIN list 1 June 2014, HaydonPerryman (FATCA systems designer for several tier 1 financial institutions) and I (primary author, Lexis Guide to FATCA Compliance) have been analyzing on a monthly basis the list that the USA provides of “approved FFIs” (foreign financial institutions). On 1 February, the IRS published its second 2015 FATCA GIIN list of “approved FFIs” (a list of the financial firms that have registered on the IRS FATCA portal). Global FFI Registration has reached 153,797.
But from what countries are these registrations? Are these DCFFI registrations or PFFIs? Which countries are leading in the registration compliance and which are lagging? Has FFI registration growth by country and region been measured over the past eight months?
Wolters Kluwer has published our complete analysis on the International Tax Law blog.
What Did Greece Promise to Get the 4 Months Extension and Billions More?
all the official documents disclosed at International Financial Law Prof Blog
Politicians and Regulators Scrambling to Explain Lack of Action Against HSBC
The political row over the Swiss Leaks revelations is building in a number of countries, as HSBC faces committee investigations in the United Kingdom, and politicians in the United States weigh the nomination of a potential attorney general who previously investigated the bank. read the full ICIJ story at International Financial Law Prof Blog
Will a New Fiduciary Standard Fix the Advisor-Client Conflict of Interests for Retirement Accounts?
read the all the conflicting opinions answering this question at International Financial Law Prof Blog
Tuesday, February 24, 2015
5 Hot Retirement Planning Topics for 2015
Whether your client is concerned with maximizing tax-preferred account options, planning for increased longevity or using their retirement accounts as estate planning vehicles, the rules have changed for 2015. ... read about them at International Financial Law Prof Blog
Financial advisers count falls fifth straight year because no replacements for retirements. Why aren't replacements graduating?
JD Graduate Careers? financial advisers count falls fifth straight year because no replacements for retirements International Financial Law Prof Blog
There were roughly 285,000 financial advisers in 2014, a 1.9 percent drop from 2013, according to a report by the Boston-based research group Cerulli Associates. The industry has lost more than 39,000 advisers, roughly 12 percent, since its peak in 2008, when there were 325,000 advisers.
Nearly half of all financial advisers are over the age of 55. Over the next decade, Cerulli expects nearly 100,000 brokers will retire. read more at International Financial Law Prof Blog
Monday, February 23, 2015
Longevity Pegged Annuities - What CPAs Need to Know About the New Rules
http://viewer.zmags.com/publication/8df8c3b9#/8df8c3b9/66
Longevity Pegged Annuities - What CPAs Need to Know About the New Rules (William Byrnes & Robert Bloink)
The Treasury Department made sparks fly when it recently issued final regulations governing qualified longevity annuity contracts (QLAC).
read the full story at CPA Journal of the New York Society of Certified Public Accountants
February FATCA Updates: GIINs and IDES
Byrnes and Perryman analyze FFI registrations and the IRS' IDES updates on International Financial Law Prof Blog
Friday, February 13, 2015
PwC's Report on the Green Book - Obama FY 2016 Budget proposes minimum tax on foreign income and PwC's analysis of other significant international tax proposals
Treasury's 'Green Book,' released February 2, 2015, outlines the Administration's FY16 Budget proposals. It explains a new proposal for a 19% minimum tax on foreign income and a one-time 14% transition tax on previously untaxed foreign income. It also significantly changes some international tax proposals made in previous Budgets. The Budget reaffirms President Obama's support for 'business tax reform' that would lower the top US corporate rate to 28% (25% for domestic manufacturing income). read it on International Financial Law Prof Blog
Islamic Banking: Some Distinguishing Regulatory Considerations
This focus of this paper is the regulation of one segment of modern Islamic finance: Islamic banking, whether conducted by stand-alone Islamic banks or “Islamic windows” within conventional interest-based banks. Consideration is given to a select group of illustrative issues that arise in connection with the regulation of Islamic banks.
see International Financial Law Prof Blog
see International Financial Law Prof Blog
Thursday, February 12, 2015
Banking giant HSBC sheltered murky cash linked to dictators and arms dealers
Secret documents reveal that global banking giant HSBC profited from doing business with arms dealers who channeled mortar bombs to child soldiers in Africa, bag men for Third World dictators, traffickers in blood diamonds and other international outlaws.
read the story at International Financial Law Prof Blog
read the story at International Financial Law Prof Blog
The Financial Industry Regulatory Authority: Not Self-Regulation after All
Broker-dealers in the United States are regulated by the Financial Industry Regulatory Authority (FINRA). Although commonly perceived to be a self-regulator, FINRA is not accountable to the industry in the way a self-regulator would be. Nor is it accountable to the public, Congress, the president, or the courts. FINRA’s structure and monopoly status shield it from close oversight. http://lawprofessors.typepad.com/intfinlaw/2015/02/the-financial-industry-regulatory-authority-not-self-regulation-after-all.html
Monday, January 26, 2015
Is Insider Trading Still a Crime after U.S. v Newman?
read about the case and the most recent pleases thrown out on International Financial Law Prof Blog
FINRA Changes Regulatory Priorities - Pushing "Best Interest of Client" in 2015 Over "Suitability Standard"
FINRA stated that a central failing FINRA has observed is firms not putting customers’ interests first.
Read the analysis of FINRA's 2015 Regulatory Priorities on International Financial Law Prof Blog
Read the analysis of FINRA's 2015 Regulatory Priorities on International Financial Law Prof Blog
Offshore Voluntary Disclosure Program's "Non-Willful" Narratives - "I Didn't Know It Was Against the Law"
read about constructing the narrative on International Financial Law Prof Blog
Friday, January 16, 2015
Luxembourg's Amazon Deal is State Aid Because of Lack of Diligence, EU Commission Decision Released. How Much Must Amazon Pay Back in Tax Relief?
down load the decision and read the analysis at International Financial Law Prof Blog
Thursday, January 15, 2015
OFAC Makes It Easier for Banks to Detect & Avoid Persons & Companies on the International Black List With Newly Released Global Format
This new sanctions list format was jointly developed by the United Nations (U.N.) and the Wolfsberg Group of International Banks in an effort to create a universal sanctions list format that can be efficiently used by governments worldwide and enhances sanctions compliance. The new format incorporates a variety of features that ensure maximum flexibility for sanctions list creators, while also limiting the need for future changes to the underlying data specification due to the standard’s adaptability.
New capabilities associated with the advanced sanctions list format are discussed on International Financial Law Prof Blog
Tuesday, January 13, 2015
Comparison of the 8 FATCA GIIN Lists (June 2014 -> January 2015): BRIC, EU, NAFTA, and Caribbean
full analysis is available at http://lawprofessors.typepad.com/intfinlaw/2015/01/more-analysis-of-fatca-giin-list-of-january-2015.html
The June 2, 2014 GIIN list contained 77,353 registrations from 205 countries and jurisdictions. Of the June registrations, 74 percent were from Model 1 IGAs that had been either signed or recognized as agreed in substance by the IRS. Approximately 20 percent of these total registrations were from Cayman Islands firms, and 37 percent of the total from the UK and its Crown dependencies and overseas territories. Cayman Islands remains the FATCA registration leader. ....
continued from Saturday's post
The June 2, 2014 GIIN list contained 77,353 registrations from 205 countries and jurisdictions. Of the June registrations, 74 percent were from Model 1 IGAs that had been either signed or recognized as agreed in substance by the IRS. Approximately 20 percent of these total registrations were from Cayman Islands firms, and 37 percent of the total from the UK and its Crown dependencies and overseas territories. Cayman Islands remains the FATCA registration leader. ....
BRIC Registrations
BRIC remains disappointing For the initial June list, Brazil led the BRIC countries with 2,258 FFI registrations, followed by Russia (514), India (246) with China only having 211. Based upon the most recent data, the BRIC countries have thus far shrugged off FATCA.
During October, India and China competed for FATCA lethargy with only ten FFIs registering from China moving it from 599 to 609 (658 as of the December list, and now 927 for 2015's initial list), and merely two from India for a total of 393 as of the November 1 GIIN list (401 as of December, 442 for January 2015). Brazil experienced the largest amount of registrations, jumping approximately 400 to 2,841 (3,179 as of December, 3,594 for 2015), whereas only 40 Russian entities registered (961 in November, 993 as of December, and 1,050 for 2015's start). .... read the full story at the International Financial Law Professor
3rd edition of Lexis' FATCA Compliance book is ready - Lexis Guide to FATCA Compliance and out soon with substantial more analysis – 1,200 pages over 54 chapters. Over 50 FATCA compliance experts from tier 1 institutions, former government officials, and professional firms have contributed to create this detailed and robust guide, filled with numerous practical examples and several chapters written specifically for the non-legal, compliance operations officer. No filler pages of publicly available documents and regurgitated regulations – it’s all beef. See the Lexis website to order a copy of this 3rd edition.
Monday, January 12, 2015
Used Motor Vehicle Odometer Tampering Leads to Money Laundering Indictment
read the full post at International Financial Law Prof Blog
The indictments charge that the Galis used fictitious dealer names to purchase high-mileage, used motor vehicles from a national vehicle leasing company. The defendants are charged with conspiring to alter the odometers in these vehicles, which they purchased in Florida, Maryland, Missouri and elsewhere, to reflect false lower mileages. The EDPA indictment alleges that in some instances, the title indicated mileage more than 100,000 miles less than the true mileage of the vehicle and as a result, the defendants received inflated sales prices for the vehicles they sold.
Friday, January 9, 2015
112 Intergovernmental Agreements and counting .... only 123 countries left out in the FATCA cold
from the headlines of International Financial Law Prof Blog
read the full post at -
http://lawprofessors.typepad.com/intfinlaw/2015/01/112-intergovernmental-agreements-and-counting-only-123-countries-left-out-in-the-fatca-cold.html
read the full post at -
http://lawprofessors.typepad.com/intfinlaw/2015/01/112-intergovernmental-agreements-and-counting-only-123-countries-left-out-in-the-fatca-cold.html
Wednesday, January 7, 2015
FATCA International Data Exchange Service Guide Now Available via IRS
International Financial Law Prof Blog:
The main function of IDES is to provide authorized users with secure exchange services for FATCA data transmissions, with the additional protection of a Public Key Infrastructure (PKI). The primary features of IDES are: read the post at International Financial Law Prof Blog
The main function of IDES is to provide authorized users with secure exchange services for FATCA data transmissions, with the additional protection of a Public Key Infrastructure (PKI). The primary features of IDES are: read the post at International Financial Law Prof Blog
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