The Resource An analysis of the Green Book's international tax enforcement provisions for U.S. persons

An analysis of the Green Book's international tax enforcement provisions for U.S. persons

Label
An analysis of the Green Book's international tax enforcement provisions for U.S. persons
Title
An analysis of the Green Book's international tax enforcement provisions for U.S. persons
Creator
Subject
Language
eng
Summary
This article examines the Green Book's international tax enforcement provisions for U.S. persons, including: strengthening the existing "qualified intermediary" system to crack down on tax evasion; impose significant tax withholding on transactions involving nonqualified intermediaries or foreign legal entities (non-QIs); additional reporting and disclosure of foreign financial accounts and foreign business entities by financial institutions and U.S. persons; impose negative presumptions for U.S. persons or non-QIs for failure to file a foreign bank account report (FBAR); impose negative presumptions regarding U.S. withholding tax on fixed, determinable, annual, or periodical (FDAP) payments to certain foreign entities; extend statute of limitations for certain reportable cross-border transactions and foreign entities to six years after filing FBAR information and returns; impose 40-percent accuracy-related penalties on understatements of income tax involving undisclosed foreign accounts; improve the foreign trust penalty; money laundering, non-income tax issues and state and local follow-on impact; sharing of FBAR information by international and state and local law enforcement and banking and securities regulators; and grant of enforcement tools to prosecute international tax evasion
Citation source
In: Taxes - the tax magazine. - Chicago. - Vol. 87 (2009),
http://library.link/vocab/creatorName
Marsan, D
Geographic coverage
International
Language note
English
http://library.link/vocab/subjectName
  • tax evasion
  • enforcement
  • tax haven
  • offshore bank
  • qualified intermediary
  • withholding tax
  • disclosure
Label
An analysis of the Green Book's international tax enforcement provisions for U.S. persons
Instantiates
Publication
Label
An analysis of the Green Book's international tax enforcement provisions for U.S. persons
Publication

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