Navigating Voluntary Disclosure Programs for FBAR and U.S. Tax Reporting


The aggressive focus against tax evasion and other criminal activities around the globe is likely to continue. In the U.S., the crackdown on taxpayers who fail to report offshore financial assets and accounts remains to be a top priority for the Internal Revenue Service (IRS)  Criminal Investigation Department, especially violations under the Foreign Bank Account Reporting (FBAR).

The Foreign Account Tax Compliance Act (FATCA): Regulatory Trends and Compliance Issues in 2020


The Foreign Account Tax Compliance Act (FATCA) landscape has been evolving in recent years. With the Internal Revenue Service’s (IRS’) and the U.S. Treasury Department’s continuous efforts to clamp down tax evasion and other criminal activities, complex reporting requirements have been instituted and several FATCA guidance have been released. Thus, significantly shaping this area of law.

Federal Tax Controversy in 2020: Preparing for IRS Enforcement Initiatives


The shifting regulatory paradigm and emerging developments in federal tax laws confront companies with increased scrutiny on their tax planning practices. As the U.S. International Revenue Service (IRS) intensifies its enforcement initiatives, compliance has become more challenging and complex than ever. Thus, making companies more vulnerable to tax controversies. Failure to address and mitigate potential tax issues could mean hefty penalties. 

Transfer Pricing Regulation in the 2020 Landscape: Maximizing Opportunities and Overcoming Challenges


Transfer pricing presents notable challenges and opportunities for multinational entities. Significantly, the rising disputes and sweeping impact of recent tax reforms have continuously reshaped its regulatory landscape and resulted in an intensified scrutiny. However, with a keen understanding of and proper compliance with the rules, transfer pricing can be substantial in positioning a business both locally and globally.

The Evolving FATCA/CRS Reporting Landscape: Changes, Challenges, and Solutions


The introduction of the Foreign Account Tax Compliance Act (FATCA) by the U.S. and Common Reporting Standard (CRS) by the Organisation for Economic Co-operation and Development (OECD) had significantly affected the compliance process of financial institutions around the globe. With the various FATCA/CRS reporting challenges that continue to hound these organizations, coupled with the COVID-19 disruption, it has been a struggle to remain compliant.

Federal Tax Controversy: Demystifying Trends, Developments, and Critical Issues


Despite deadline extensions and a challenging environment caused by the COVID-19 outbreak, the Internal Revenue Service (IRS) continues its strict tax enforcement. Audit activity is expected to be more aggressive as governments grapple to cover the current budget deficit and falling revenues. However, businesses facing assessments or controversies may be able to settle cases more favorably under the present financial crisis.

New IRS Regulations on Qualified Opportunity Zones: What You Must Know and Do


In April 2019, the Internal Revenue Services (IRS) released its second set of new regulations on the Qualified Opportunity Zone (QOZ) program. The additional guidelines aim to give light on the initial regulations released last 2018. However, several open questions still remain, that investors and related practitioners must be continuously proactive in monitoring the latest regulatory trends and development. Understanding the latest updates and how these might affect their businesses also will help them maximize opportunities while mitigating potential risks and pitfalls.

How to Effectively Handle State and Federal Tax Controversy: Practical Tips and Strategies Explored


In recent years, state and local governments have become more proactive in pursuing additional revenue through stricter application of their tax laws. Additionally, revenue authorities have also significantly widened their search for new revenues. These have made taxpayers grapple with problems and lawsuits at the audit and novel roles.

A Comprehensive Guide on Sales and Use Tax: Demystifying Trends, Developments, and Legal Challenges


Emerging trends and developments have brought sweeping changes to the sales and use tax landscape. In recent years, economic nexus legislations, following the South Dakota vs. Wayfair decision, have continuously affected corporations from various states. Adding to the challenges are the impacts brought by COVID-19, which include cash flow and state obligation issues. In response, new rules for deferral reliefs on sales and use tax filing and payment have now been laid down.

Transfer Pricing and COVID-19 Implications: Key Issues and Best Practices


The economic downturn brought by the COVID-19 pandemic has profoundly impacted the transfer pricing landscape. Multinational enterprises (MNEs) are dealing with serious transfer prices issues, supply chain disruptions, and restructuring expenses. In response to these growing repercussions, the Organization for Economic Co-operation and Development (OECD) recently published guidance on transfer pricing policies and clarified the application of the arm’s length principle. It also underscored the compliance challenges faced by MNEs.

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