The " Panama Papers" (purloined documents of the Mossack Fonseca law firm), the Paradise Papers, the " LuxLeaks", and other disclosures by the International Consortium of Investigative Journalists and Wikileaks, the Birkenfeld and UBS client lists, and initiatives of the OECD and the European Union led to a web of bilateral agreements and rules, including EU Council Directive 2014/107/EU on mandatory automatic exchange of tax-relevant information. Treasury's pursuit of Swiss and other foreign banks: the UBS, Credit Suisse, HSBC, Wegelin and other client lists. There are other sources: "quiet disclosure" where a taxpayer submits amended or late tax returns and declarations (see Noam Noked, "The Future of Voluntary Disclosure", Tax Notes, Aug 6, 2018, p. Since about 2005 the IRS has aggressively pursued violators resident in the U.S.A., including some who came to its attention through voluntary disclosure in amnesty programs. Persons and financial institution enablers. The essay collects links to documentation of known IRS prosecutions and IRS-reported civil penalties imposed against noncompliant U.S. Persons" (defined below) report annually on foreign financial assets. This bibliographic essay addresses the cross-border enforcement of citizenship-based taxation by the United States, in particular the requirement that "U.S. Tax Discrimination Cases, Human Rights and Other Issues Peripheral to the FATCA Question Expatriation, Conflict of Status, "Covered Expatriates", Estates and Trusts Origins of FATCA: Banks Alleged to be Involved in Tax Evasion Substantial Penalties FATCA, Know Your Customer (KYC), Anti-Money Laundering (AML) and Foreign Financial Institutions (FFIs): Denial of Financial Services Abroad to "U.S. Enforcement and Partial Abatement Matters Passive Foreign Investment Companies (PFIC)
Foreign Account Tax Compliance Act (FATCA) He has begun a project analyzing the limits of national autonomy in matters of nationality under European law.
#Lookthrough issueserisa series
His previous work in this series is "Update: Finding the Law: the Micro-States and Small Jurisdictions of Europe" and "A Research Guide to Cases and Materials on Terrorism". 11-12, 2004 and "'Islamic land': Group Rights, National Identity and Law", 3 UCLA J.
849 (2001), "Birthright citizenship as nationality of convenience", Proceedings, Council of Europe, Third Conference on Nationality, Strasbourg, Oct. 1 (1996), "Nationality and the Unrecognized State", 50 Int'l & Comp. Among his publications are "Conflict of Laws in the Discharge of Debts in Bankruptcy", 5 Int'l Insolvency Rev. He now lives in Switzerland where he writes on private international law issues, especially in the fields of nationality and tax. (University College London) and of Licencié en droit européen et international, Maître & Docteur en droit ( Louvain-la-Neuve) and is a member of the New York Bar. Foreign Service Officer who served in Seoul, Abidjan, London, Tehran, Paris, Algiers and Geneva.
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