Go To Jail Free Card

Go To Jail Free Card

One of the most frequent excuses for NQIs not complying with reporting obligations, over and above lack of awareness, has always been the failure of the IRS to penalise firms for problems in filing. I thought the community should be aware that we are now starting to...
FATCA Wars, Episode 2 – Attack of the Regs

FATCA Wars, Episode 2 – Attack of the Regs

When we first came up with the idea of an ‘interim periodic review’ or IPR, we hoped it might generate a little interest. Well it did, in spades! We’ve now conducted a number of IPRs for clients in the UK, continental Europe and in Asia, and we have more to do in the...
IPRs: The Story Continues…

IPRs: The Story Continues…

I started this blog series from the premise that FATCA has control and oversight mechanisms consisting of two parts: a continuing obligation on the responsible officer (RO) to declare any events of default or material failure of control adequacy, and a three year...