Tax News

In light of the expected implementation of the CRS agreement in Israel for automatic exchange of information between tax authorities, and as part of the increasing efforts of the Israeli Tax Authorities (“ITA”) to detect tax evaders and to expose unreported worldwide income of Israeli tax residents together with the success of the last voluntary disclosure procedure that expired at the end of 2016, the ITA published a new "voluntary disclosure procedure" on December 12, 2018.

The amendment to the Israeli Money Laundering Law (hereinafter; “the Law”), which was approved by the Knesset on December 4th and 5th, will take effect in the coming days. The amendment lowered the threshold for reporting any cash brought into or taken out of Israel, from NIS 100,000 to NIS 50,000. For land crossings, the threshold is NIS 12,000.

According to U.S. law, if you have a financial interest in or signature authority over a foreign financial account, including a bank account, brokerage account, mutual fund, trust, or other type of foreign financial account, exceeding certain thresholds, the Bank Secrecy Act may require you to report the account yearly to the Department of Treasury by electronically filing a Financial Crimes Enforcement Network (FinCEN) 114, Report of Foreign Bank and Financial Accounts (FBAR).

By William Hoke

Reproduced with permission from Tax Notes International, Oct. 9, 2017, pp. 136-137. Copyright 2017 by Tax Notes (https://www.taxnotes.com/)

Five days after Israel’s central bank told banks under its supervision to scale back their foreign activities following investigations by U.S. authorities, Bank Hapoalim Ltd. said its board of directors has authorized the termination of its Swiss subsidiary and the sale of the unit’s assets.

After months of discussions between the Israel Tax Authority (ITA), the Ministry of Finance, and the Ministry of Justice, it seems that the Israeli Voluntary Disclosure Program (Israeli VDP) will be renewed in January 2018. The new program will be similar to the previous Israeli VDP that commenced on December 31, 2016.  In the event that all conditions of the program are met, which includes a voluntary disclosure made out of good faith effort, the taxpayer will be able to disclose the unreported income, and pay the taxes due.

If you are a Non-UK Domiciled individual (hereinafter: "ND") who is tax resident in the UK, there are two different systems of taxation that could apply to you.

Israeli resident individuals are subject to Israeli tax on their worldwide income and capital gains. Effective January 1, 2007, "New Residents" and "Senior Returning Residents" (Israelis who have lived abroad for at least 10 years) are both entitled to the same package of tax benefits, which include a 10-year exemption from reporting and payment of tax from all non-Israeli sourced income and capital gains, even if the foreign assets were acquired after moving to Israel.

According to the 2014 Offshore Voluntary Disclosure (hereinafter: “OVDP”), the offshore penalty of 27.5% increases to a 50% penalty in any of the following circumstances:

Reproduced with permission from International Tax Monitor, 165 ITM, 8/28/17. Copyright 2017 by The Bureau of National Affairs, Inc. 800-372-1033 http://www.bna.com 

By Mirit Reif, Adv.

Recently, the Israeli Supreme Court ruled that a married businessman’s tax residency was in Israel, thus impacting his tax obligations in Israel, even though he spent a significant amount of time outside of Israel, tending to his businesses abroad and had “marital relationships” with other women while he was there.

The taxpayer had a wife and four children living in Israel. He worked in Israel and since 1991, started to engage in business activities in two other unspecified countries.

As mentioned in our previous articles on this subject, the Economic Arrangement Bill (Legislative Amendments to Implement the 2017-2018 State Budget) 5776-2016, was published by the Israeli government on December 29, 2016. Various tax amendments were made including the new Third Apartment Tax Bill.

This Bill imposed a tax on anyone who owns 3 apartments and more, at a maximum amount of NIS 18,000 tax per year, per apartment. The Israeli Tax Authority (ITA) recently postponed the deadline for reporting and payment under this new Bill until September 1, 2017.

On August 2, 2017, Mr. Donald Fort, the new IRS Criminal Investigation (CI) Division Chief, announced the establishment of two investigation initiatives: a nationally coordinated investigations unit and a dedicated international tax enforcement group. Fort explained that the new unit will provide a way to more effectively coordinate investigations that have nationwide impact, since it will report to CI’s frontline executives. The unit will use data analytics “to help identify and develop areas of noncompliance,” Fort said.

As mentioned in our previous article on this subject, the Economic Arrangement Bill (Legislative Amendments to Implement the 2017-2018 State Budget) 5776-2016, was published by the Israeli government on December 29, 2016.

This Bill included a tax to be imposed on anyone who owns 3 apartments and more, at a maximum amount of NIS 18,000 tax per year, per apartment.

Lately, we were contacted by several American citizens who received letters from Bank Hapoalim requesting that they provide proof that their account at the bank was properly declared to the Unites States tax authorities (the IRS). In addition, the bank requested from the clients to sign on a waiver of confidentiality and consent to report to the IRS information regarding the account. Even if the American citizen refuses to sign the waiver, the bank may still be required to transfer the information to the United States.

As mentioned in our previous article on this subject, the Economic Arrangement Bill (Legislative Amendments to Implement the 2017-2018 State Budget) 5776-2016, was published by the Israeli government on December 29, 2016.

Various tax amendments were made including the new Multiple Apartment Tax Bill. This Bill imposes a tax on anyone who owns 3 apartments and more, at a maximum amount of NIS 18,000 tax per year, per apartment.

IRS’s Large Business and International (LB&I) Division announced in January 2017, thirteen initial issue-based campaigns as a new audit strategy. The campaigns span a broad range of topics and intended to offer a comprehensive response to compliance risks.

Rumors have it that a new Israeli Voluntary Disclosure Program (Israeli VDP) will be announced in September 2017. This was mentioned by an Israeli Tax Authority representative during the tax forum meeting of the Israeli Bar Association. In the event that all conditions of the program are met, which includes a voluntary disclosure made of good faith effort, the taxpayer will be able to disclose the unreported income, and pay the taxes due.

The Israel Tax Authority (ITA) recently received information of approximately 30,000 accounts owned by Israeli residents that were held in financial institutions in the United States during 2014. This list is added to the previous information that was released by the United States in January of over 35,000 accounts owned by Israeli residents that were held in financial institutions in the United States during 2015, and to the account information of 8,000 Israelis obtained from HSBC Switzerland recently.

by Mirit Reif

In 2015, a new section of the tax code, called “Revocation or Denial of Passport in Case of Certain Tax Delinquencies", was approved by both the House of Representatives and the Senate.

On January 11, 2017, the Israel Tax Authority (ITA) posted draft regulations relating to the taxation of virtual currencies.

Individuals that own an apartment in Israel (hereinafter “taxpayer”) and receive rental income from it, need to check if they owe tax on the income.  This article acts as a guide for tax payments and tax relief on rental income of residential apartments in Israel.

There are three options that a taxpayer can choose from. Each option can be chosen for each rental apartment separately:

by Mirit Reif Adv

On January 5, 2017, the Knesset Finance Committee approved the revised regulations regarding the grant mentioned in the Third Apartment Tax Bill. The regulations apply for anyone selling an apartment from January 1, 2017.

During the last months of 2016, and as part of the FATCA agreement between Israel and the United States, the Israel Tax Authority (ITA) transferred to the United States Internal Revenue Service (IRS) data relating to Israeli financial accounts owned by American citizens, during 2014 and 2015. In exchange, the ITA received information of over 35,000 accounts owned by Israeli residents that are held in financial institutions in the United States.

The Economic Arrangement Bill (Legislative Amendments to Implement the 2017-2018 State Budget) 5776-2016 was published by the Israeli government. Various tax amendments were made including the final new Third Apartment Tax Bill (“the Bill”).

Our annual overview of the most important International Information Forms for U.S. tax payers living abroad for the 2016 Tax Return Filing Season, includes:   FinCEN Report 114 (FBAR), FinCen Form 105, Form 926, Form 1042-S, Form 3520 & 3520-A, Form 5471, Form 5472, Form 8621, Form 8858, Form 8865, Form 8938, Form BE-10

The Israeli Tax Authorities recently published the following English guide about tax benefits for new immigrants (olim) and returning residents who became citizens since January 1st 2007.

On August 12, 2016, the Israeli budget proposal for 2017-2018, was approved by the Israeli governmen, includes twelve clauses that were suggested as amendments to the Israeli tax code, and that are expected to be discussed for approval in November in the Knesset.  These clauses all have the same goal of reducing tax evasion and increasing tax enforcement laws.

The Israeli Ministry of Finance proposed to impose tax on owners of three or more apartments. If this proposal is approved, a new annual tax will be imposed on owners of three apartments or more, starting January 1, 2017.

The United States Court of Appeals for the Ninth Circuit recently reversed the ruling issued by the United States District Court of California, resulting in the verdict that online gambling accounts do not have to be reported on an FBAR form.

On June 15th, 2016, the Israeli Tax Commisioner, Mr. Moshe Asher, announced that the deadline of the Israeli Voluntary Disclosure Programs has been extended until the end of 2016.

During April 2016, the Israel Tax Authority (hereinafter: “the ITA”) announced several changes that will impact many taxpayers located in Israel and abroad. Here is a short summary of the main changes:

Israel signs the Multilateral Competent Authority Agreement for the automatic exchange of Country-by-Country reports and the CRS Multilateral Competent Authority Agreement.

In order to implement the FATCA agreement, the Competent Authorities signed on March 23, 2016 the Competent Authority Agreement (the “CAA”), as per Article 3(6) of the FATCA agreement that requires the Competent Authorities to enter into an agreement or an arrangement in order to establish the rules and procedures necessary in order to implement the FATCA agreement.

According to the 2014 Offshore Voluntary Disclosure (hereinafter: “OVDP”), the offshore penalty of 27.5% increases to a 50% penalty in any of the following circumstances:

According to the 2014 Offshore Voluntary Disclosure (hereinafter: “OVDP”), the offshore penalty of 27.5% increases to a 50% penalty in any of the following circumstances:

The IRS has just released fact sheet FS-2016-8, highlighting 2015 tax law changes, including the extension of several tax benefits, newly available tax-favored accounts for some individuals with disabilities as well as starter retirement accounts, revised standard mileage rates, a one-rollover-per-year limit for IRA owners, and healthcare updates.

According to the 2014 Offshore Voluntary Disclosure (hereinafter: “OVDP”), the offshore penalty of 27.5% increases to a 50% penalty in any of the following circumstances:

In continuation to the tightening of enforcement from the Israel Tax Authority to detect tax invaders among those who are not reporting their income from apartment rental, here is an updated short guide intended to introduce you to the legal options for tax payments and tax relief on rental income of residential apartments in Israel.

The Surface Transportation and Veterans Health Care Choice Improvement Act of 2015, which was enacted on July 31, 2015, modified the FBAR filing deadline from June 30th to April 15th to align it with the filing deadline for individual income tax returns.

According to the 2014 Offshore Voluntary Disclosure (hereinafter: “OVDP”), the offshore penalty of 27.5% increases to a 50% penalty in any of the following circumstances:

A new section of the tax code, called “Revocation or Denial of Passport in Case of Certain Tax Delinquencies", was recently approved by both the House of Representatives and the Senate.

הגברת האכיפה בנושא ההון השחור עולה מדרגה וברשות המסים כבר מחייבים את הבנקים לשיתוף פעולה שיעזור לתפוס את המתחמקים מתשלום מסים. אם יש לכם מה להסתיר - זה הזמן לפנות להליך הגילוי מרצון שתוקפו יפוג בחודש יוני הקרוב.

 

בזמן האחרון רבים בישראל מתבקשים על ידי הבנקים לחתום על מסמכים לגילוי פרטים, שאם לא כן חשבונם יוקפא לאלתר, והכל במסגרת המגמה השלטת במדינות המערב – הגברת שיתוף הפעולה בכל הקשור למתחמקים מתשלום מיסים.

According to the 2014 Offshore Voluntary Disclosure (hereinafter: “OVDP”), the offshore penalty of 27.5% increases to a 50% penalty in any of the following circumstances:

בזמן האחרון אנחנו מקבלים פניות מהלקוחות שלנו, שהם לאו דווקא אזרחי ארה"ב, לגבי מסמכים שהבנק מבקש שיחתמו, וללא חתימתם, חשבונם יוקפא לאלתר.

Be informed! It is important to review the latest FATCA information and/or any bank documents regarding offshore tax evasion and exchange of information between countries, such as the one titled "Declaration of Residency and Waiver of Secrecy Rights." Failure to provide the requested information may lead to your account/s being frozen.

According to the 2014 Offshore Voluntary Disclosure (hereinafter: “OVDP”), the offshore penalty of 27.5% increases to a 50% penalty in any of the following circumstances:

According to the 2014 Offshore Voluntary Disclosure (hereinafter: “OVDP”), the offshore penalty of 27.5% increases to a 50% penalty in any of the following circumstances. 

As we had mentioned on September 6, 2015, the two temporary provisions of the Israeli Voluntary Disclosure Programs (the Anonymous Track and the Fast Track) that were supposed to end on September 6, 2015, had been extended for an unknown period. Today, the ITA announced that the new deadline for submissions under these provisions is June 30, 2016.

The Israeli Tax Authorities announced today that the September 6, 2015 amnesty filing deadline has been extended, the new deadline yet to be published. 

According to the 2014 Offshore Voluntary Disclosure (hereinafter: “OVDP”), the offshore penalty of 27.5% increases to a 50% penalty in any of the following circumstances. 

The Israel Tax Authority requested to postpone the transfer date of FATCA information to the IRS.  The United States government agreed to Israel's request to postpone this date to September 30, 2016. 

On April 1, 2015, the basic exclusion amount (i.e., the amount of property that can pass free of New York State estate tax) was increased to $3,125,000 and will be increased incrementally through January 1, 2019, after which the basic exclusion amount will be tied to the federal exemption amount.

According to the 2014 Offshore Voluntary Disclosure (hereinafter: “OVDP”), the offshore penalty of 27.5% increases to a 50% penalty in any of the following circumstances.

On July 31, 2015, President Obama signed into law H.R. 3236, the "Surface Transportation and Veterans Health Care Choice Improvement Act of 2015”, which, among other issues, changes the due dates for partnership and C corporation’s tax returns, several common tax returns, the FBAR and overrules the Supreme Court’s Home Concrete & Supply, LLC decision.

Set forth below is our annual overview of the most important International Information Forms for expatriate tax returns, for the 2014 Tax Return Filing Season.

A BE-10 Report is required of any U.S.person that had a foreign affiliate - that is, that had direct or indirect ownership or control of at least 10 percent of the voting stock of an incorporated foreign business enterprise, or an equivalent interest in an unincorporated foreign business enterprise - at anytime during the U.S. person's 2014 fiscal year.

מעתה, יש לקחת לתשומת הלב, שבעצם מילוי הטופס לחידוש הדרכון האמריקאי, ובו פרטים אישיים רבים, אתם מאשרים מראש כי פרטים אישיים אלה יועברו בצורה ישירה לרשות המס בארהב (IRS).

The April 15th deadline for filing US tax returns has passed.  Here are some strange and weird taxes and tax deductions:

Individuals who renew their US passport need to take into consideration that their Social Security Number (SSN) and country of residency will be forwarded to the IRS.

The efforts made by the Israeli Tax Authorities (ITS) to combat unreported overseas accounts held by Israelis are beginning to yield results. Swiss banks have toughened their conditions for Israelis continuing to hold accounts.

The Israeli Tax Authorities recently published the following English guide to tax benefits for new immigrants and returning residents who became citizens since January 1st 2007.

In continuation to the tightening of enforcement from the Israel Tax Authority to detect tax invaders among those who are not reporting their income from apartment rental, here is a short guide intended to introduce you to the legal options for tax payments and tax relief on rental income of residential apartments in Israel.

The IRS announced the opening of the International Data Exchange Service (IDES) for enrollment. Financial institutions and host country tax authorities will use IDES to securely send their information reports on financial accounts held by U.S. persons to the IRS under the Foreign Account Tax Compliance Act (FATCA) or pursuant to the terms of an intergovernmental agreement (IGA), as applicable.

On December 25, 2014, the Israel Tax Authority (the "ITA") extended the deadline for certain reporting requirements for Foreign Settlor Trusts in Israel. The previous deadline which was December 31, 2014, has now been extended to June 30, 2015. Here are details about which foreign trusts are required to report and pay taxes in Israel.

If you have an undisclosed foreign financial account in an institution already under IRS investigation, the penalty for the Offshore Voluntary Disclosure Program can be raised from 27.5% to 50%. See the full list of institutions under investigation here.

The Israeli Tax Authorities published an announcement last night postponing the original date of December 31, 2014 for registration and submission by "Family" Trusts of the forms for election of the appropriate tax route (i.e., either 25% or 30%).

If you have over $50,000 in foreign financial assets, you may be required to file IRS Form 8938. And if you don't, penalties are steep. See all the details: when you're obligated and what you need to report.

The Bank of Israel recently sent Israeli banks a draft procedure requiring banks to receive from their foreign clients a declaration that they have paid the required tax on the income in their Israeli bank accounts in their country of residence.

Nations all over the world are signing agreements to cooperate on exchanging tax information and cracking down on offshore tax havens. Does this spell the end for offshore tax evasion?

Israeli banks are requesting from their former clients that are American citizens to come to the bank and sign on a W9, even though the relevant account has been closed for a few years. What does this mean and what should you do?

On November 18, 2014, the Israeli Tax Authorities ("ITA") published explanations and forms in English relating to the various voluntary disclosures programs that are now available. Here are summaries of the details and where you can find the official explanations.

International banks refuse to do business with US citizens. Renunciation of American citizenship on the rise. FBI agents training with assault rifles. If it sounds like Hollywood's newest thriller, it's not. Brought to you by FATCA and FBAR, the financial landscape is changing for American citizens who thought their foreign assets were safe from the eyes of the IRS.

As part of the increasing efforts of the Israeli Tax Authorities ("ITA") to detect tax evaders and to expose unreported worldwide income of Israeli tax residents, the ITA has published today a New Voluntary Disclosure Program which will replace the current program.

The IRS recently issued a consumer alert providing taxpayers with additional tips to protect themselves from telephone scam artists calling and pretending to be with the IRS.

As the world becomes increasingly globalized it is becoming easier for all taxpayers to make, hold, and manage investments through financial institutions outside of their country of residence. Offshore tax evasion is a serious problem for countries all over the world and they therefore have a shared interest in cooperating with each other against tax evasion whilst protecting the integrity of their tax systems. One way to fight against tax evasion is through exchange of information between countries.

עו"ד דייב וולף ועו"ד עדי בן יאיר-יוסף פרסמו כתבה באתר "פסק דין" לגבי תוכנית רשות המיסים לשתף מידע עם מדינות ברחבי העולם. מטרת השיתוף? למצוא היכן ישראלים שומרים הון שחור והכנסה לא מדווחת. אך רשות המיסים עכשיו נותנת הזדמנות לאלו שלא דיווחו כראוי לדווח עכשיו - ללא חשש של האשמה פלילית.

More wealthy Chinese are coming to the USA than ever before. Chinese corporations are investing in the USA. And the IRS is watching. These presentations - delivered in China, in both English and Chinese - provide a comprehensive picture of the financial landscape for US citizens who are residents of China and Chinese citizens who are or plan to be residents of the USA.

Dave Wolf, Adv. was interviewed by Philip Stein on Philip Stein and Associates' weekly podcast. The topic of this short and informative podcast: BitCoin and its tax ramifications.

The IRS just announced major changes in its Offshore Voluntary Disclosure program. Because the implementation of the Foreign Account Tax Compliance Act (FATCA) and the IRS and Department of Justice offshore enforcement efforts continue to raise the risk of detection of taxpayers with undisclosed foreign accounts and assets for the foreseeable future, the IRS determined that the OVDP should be modified. The changes reflect a greater understanding of the fact that many taxpayers were simply unaware of their filing obligations. On the other hand, the 27.5% FBAR penalty has been raised to 50% in some circumstances.

לפי הדין בארה"ב כל אזרח אמריקאי חייב לדווח על כל הכנסותיו בעולם באשר הן, ללא קשר למקום מגוריו. אי-ציות לחובת הדיווח מהווה עבירה אזרחית בנוסף לעבירה פלילית. בעקבות חוקים חדשים שיאפשרו לרשות המיסים בארה"ב לאתר כל אזרח והחשבונות שלו, הבאנו פה סקר הסיכונים למי שלא דיווח, והאופציות לתיקון.

The Israel Tax Authority announced that they have come to an agreement with the U.S.A. regarding the Model 1 FATCA agreement with the IRS.

Many US citizens with foreign financial interests feel stuck. They haven't been reporting all their income and accounts, and now they either have to wait for their foreign banks to report them to the IRS under FATCA, or to report themselves and face stiff penalties. Aren't there any better options? In fact, there are. The IRS offers four.

The US-Israel tax treaty states that US Social Security payments to residents of Israel will not be taxed by Israel. But the definition of "resident" may not apply to American who made aliyah in the past 10 years, potentially leaving their Social Security open to taxation.

The Foreign Account Tax Compliance Act (FATCA) חוקק בשנת 2010. חוק זה הוא התפתחות חשובה ומהווה חלק ממאמצי ארה"ב להיאבק בהעלמת מיסים של אזרחיה שבבעלותם חשבונות והשקעות מחוץ לארה"ב.

Set forth below is our annual overview of the most important International Information Forms for expatriate tax returns, for the 2013 Tax Return Filing Season.

On January 29, 2014 a government bill was published regarding exchange of information between Israel and other countries (hereinafter "the Bill"), that do not necessarily have a double taxation agreement with Israel. The Bill describes conditions and limitations for the exchange of information and assistance between the two countries.

The Bank of Israel ordered Israeli banks today to prepare to implement the Foreign Account Tax Compliance Act (FATCA) and not to wait for an Israeli-US agreement on the exchange of tax data. This development is quite surprising as usually countries sign the FATCA agreement first before starting the implementation of FATCA rules.

With tax season coming up, US taxpayers living abroad or with financial interests abroad are hearing the term "FATCA" accompanied by threatening stories about how their information will be given by foreign banks to the IRS without their knowledge. This article explains FATCA and its consequences in an easy-to-understand way.

Do you need to file a Report of Foreign Bank and Financial Accounts (FBAR) this year? These questions and answers cover who needs to file, how to file, exactly what to report and more. Take a look and make sure you're informed.

China has announced new foreign asset reporting requirements for Chinese residents including individuals residing in the country for more than a year and corporations registered in China. With more assets requiring declaration and more categories of residents required to declare, the new requirements resemble the FATCA of the USA and the UK.

In light of all the commotion regarding FATCA and the obligation that all US citizens have to report and pay taxes on their worldwide income regardless of where they live, some people are considering giving up their US citizenship claiming that is it more of a burden than a prerogative. This act is called expatriation which is defined by the IRS as an act of relinquishing U.S. citizenship and/or terminating long-term residency.

In August 2013, the Israel Tax Authority (ITA) launched a targeted enforcement operation to detect tax evaders among the owners of luxury apartments in Tel Aviv. This operation resulted in the findings of hundreds of thousands of shekels of unreported annual income. Many of these apartment owners were foreign residents who rented out their apartments without reporting the rental income to the ITA.

Dave Wolf spoke at the U.N. International Court of Justice in the Hague, the Netherlands. Dave was invited to speak at the three day conference which was attended by over 120 judges, lawyers and professors from all continents and spoke about FBARs, FATCA and International Exchange of Information Agreements.

Foreign-resident settlor trusts were in general exempt from Israeli Income Tax on foreign income. A new Law is changing this as of January 1, 2014.

The Swiss parliament approved on Monday a new agreement with the U.S.A. under which Swiss banks, including about 100 second-tier banks, will now have to turn over information about American account holders to the U.S. government.

The IRS reminded taxpayers that effective July 1, 2013, TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), must be filed electronically. To register for the service, please go to the U.S. Department of Treasury website.

This article, in English and Chinese, highlights the legal results of tax crime convictions, immigration status, and deportation.

On Monday May 27th Dave Wolf gave a lecture for the Chengdu Bar Association International Law Section in Chengdu, Sichuan in China. Dave spoke about the latest IRS developments regarding the I.R.S. Voluntary Disclosure Program and FATCA.

April 15th is on its way. And although US expats get an extended deadline, taxes are in the air. Five important tips U.S. taxpayers with foreign income should know for their income tax returns.

New regulations like FATCA are designed to make it harder and harder to evade US taxes by earning or investing money overseas. If you haven't been so careful about filing US taxes, what are your options now?

Israeli banks put pressure on U.S. customers due to the Foreign Account Tax Compliance Act (FATCA)

After weeks, indeed months of proposals and counter-proposals, seemingly endless negotiations and down-to-the-wire drama, Congress has passed legislation to avert the tax side of the so-called "fiscal cliff." The American Taxpayer Relief Act permanently extends the Bush-era tax cuts for lower and moderate income taxpayers, permanently "patches" the alternative minimum tax (AMT), provides for a permanent 40 percent federal estate tax rate, renews many individual, business and energy tax extenders, and more.

The Globes Newspaper, Isreal, published a story about a meeting regarding cooperation to fight tax avoidance and compliance between the heads of the Israel Tax Authority and the IRS.

What is FATCA and what does it mean for you? This article explains FATCA and how it impacts you.

The U.S. Department of the Treasury today announced that it is engaged with more than 50 countries and jurisdictions around the world to improve international tax compliance and implement the information reporting and withholding tax provisions commonly known as the Foreign Account Tax Compliance Act (FATCA).

The IRS released an Announcement on October 24, 2012 postponing and clarifying certain timelines for the compliance by withholding agents and foreign financial institutions (FFIs) with due diligence and related requirements under the Foreign Account Tax Compliance Act (FATCA).

Those who refuse to do so risk having their applications denied or existing accounts frozen.

The IRS announced yesterday over Labor Day weekend a new streamlined filing compliance procedure for non-resident U.S. taxpayers to go into effect on September 1, 2012. These procedures are being implemented in recognition that some U.S. taxpayers living abroad have failed to timely file U.S. federal income tax returns or Reports of Foreign Bank and Financial Accounts (FBARs), Form TD F 90-22.1, but have recently become aware of their filing obligations and now seek to come into compliance with the law. These new procedures are for non-residents including, but not limited to, dual citizens who have not filed U.S. income tax and information returns.

June 26, 2012 - WASHINGTON - The Internal Revenue Service today announced a plan to help U.S. citizens residing overseas, including dual citizens, catch up with tax filing obligations and provide assistance for people with foreign retirement plan issues.

The Treasury Department has issued on June 22, 2012 two separate joint statements with the governments of Japan and Switzerland that express the countries' mutual intent to pursue a framework of intergovernmental cooperation with the United States for implementing the Foreign Account Tax Compliance Act (FATCA), as enacted in the Hiring Incentives to Restore Employment (HIRE) Act of 2010.

Your Foreign Bank Account & Implementation with Tax Lawyer Dave Wolf - Dave is interviewed by CPA Philip Stein about the IRS taking another shot at addressing off-shore account reporting and the best ways for people to prepare their foreign accounts.

The Treasury Department ("Treasury") and the Internal Revenue Service ("IRS") issued proposed regulations on February 8, 2012, moving forward towards the implementation of the Foreign Account Tax Compliance Act ("FATCA").

Haaretz ran an article about the new IRS tax amnesty and Hacohen Wolf was interviewed for the article.

During the fourth quarter of 2011, there were many important federal tax developments that now have a direct impact on 2012. This letter highlights some of the more important federal tax developments for you.

The Internal Revenue Service today reopened the offshore voluntary disclosure program to help people hiding offshore accounts get current with their taxes and announced the collection of more than $4.4 billion so far from the two previous international programs.

Set forth below is our annual overview of the most important International Information Forms for the 2012 Tax Filing Season.

Effective for 2011 tax returns, a U.S. taxpayer who during a taxable year, holds any interest in a specified foreign financial asset (SFFA) must attach the new Form 8938 to his or hers income tax return if the aggregate value of all such assets exceeds $ 50,000. This new reporting requirement was added as part of the Foreign Account Tax Compliance Act (FATCA)...

(Mirit Reif, Adv. & Yoni Van-Leeuwen, Adv) - Starting November 15, 2011, the Israeli Tax Authority (ITA) has initiated a Voluntary Disclosure Procedure for Israeli residents that have income from assets, accounts and entities outside of Israel, to now come forward and voluntarily disclose them. This procedure will only be available until June 30, 2012.

(Reuters) - The U.S. pursuit of offshore tax evaders is widening to include Israel, where U.S. authorities are scrutinizing three of Israel's largest banks over suspicions their Swiss outposts helped American clients evade taxes, people briefed on the matter said.

Due to the potential impact of Hurricane Irene, the IRS has extended the due date for offshore voluntary disclosure initiative requests until September 9, 2011. For those taxpayers who have not yet submitted their request and any documents, the following actions are necessary by September 9, 2011:

IRS Extends Deadlines for FATCA Compliance for Foreign Financial and Non-Financial Institutions. August 8th, 2011, the Internal Revenue Service issued Revised Notice 2011-53 (the "Notice"), which sets forth a timeline for the implementation of certain provisions of the Foreign Account Tax Compliance Act ("FATCA"). While FATCA technically is effective from January 1, 2013, the Notice extends various deadlines for withholding, reporting and other obligations under FATCA as described below.

The Foreign Account Tax Compliance Act ("FATCA") requires any U.S. person holding foreign financial assets with an aggregate value exceeding $50,000 (determined by combining the fair market value of each asset) to report certain information about those assets on a new form that is currently being developed by the IRS (Form 8938).

U.S. citizens are required to file a Report of Foreign Bank and Financial Accounts (FBAR), Treasury Department Form FinCEN Report 114, each year if they have a financial interest in or signature authority over financial accounts, including bank, securities or other types of financial accounts, in a foreign country, if the aggregate value of these financial accounts exceeds $10,000 at any time during the calendar year.

The 2011 tax filing season is in full swing and this is a good time to recall all of the international information returns that you may have to file or collect:

On February 8, 2011, the U.S. Tax Authorities (the IRS) announced a second Offshore Voluntary Disclosure Initiative (the "2011 OVDI") intended to bring more taxpayers into compliance with the tax rules and bring offshore money back into the U.S. tax system.

The Internal Revenue Service announced today (2/8/11) a special voluntary disclosure initiative designed to bring offshore money back into the U.S. tax system and help people with undisclosed income from hidden offshore accounts get current with their taxes. The new voluntary disclosure initiative will be available through Aug. 31, 2011.

On December 21st, 2010, President Obama signed the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (the "Act") into law. As anticipated in our last Tax Alert from December 7th, 2010, the Act extends the Bush era tax rates for individuals for the years 2011 and 2012 and contains important business incentives and temporary modifications to the estate, gift and generation-skipping transfer tax rules.

In his speech for the 23RD Annual Institute on Current Issues in International Taxation in Washington, DC on December 9, 2010, IRS Commissioner Douglas Shulman said that the IRS is “seriously considering” a new partial IRS Amnesty Program for taxpayers who report secret offshore bank accounts.

President Obama announced last night, December 6, 2010 a tentative agreement with Congressional Republicans for a temporary extension of the 2001 and 2003 Bush-era tax cuts.