On 24 July 2015, the Supreme Administrative Court in Warsaw gave its decision in the case of Cyprus company v. Polish Minister of Finance (II FSK 1455/13 – Wyrok NSA z 2015-07-24). The case involved a private investment fund registered in Cyprus (the Applicant), which applied to the Ministry of Finance of Poland for a […]
Requesting Penalty Abatements for Failure to File Forms 5471, 5472, FATCA and FBAR This CLE/CPE webinar will provide tax counsel with a detailed discussion of best practices for requesting abatements of IRS penalties due to failure to properly file required international information forms such as the FBAR, Form 8938, and Forms 5471 and 5472. The […]
The Ministry of Finance of Cyprus announce on 08 September 2015 the conclusion of the negotiations with Ukrainian Ministry of Finance. The two Contracting States agreed to a Protocol that will amend the Convention for the Avoidance of Double Taxation and the prevention of fiscal evasion with respect on taxes on income when it expire. […]
As stated in a publication of the German Bundestag, in terms of the “Luxemburg Leaks” affair 140 cases involving German tax law were uncovered. The majority of the unveiled tax structures are reported to be known “patent box schemes” as well as other so called “hybrid” tax structures. German officials plan to implement automatic exchange […]
Dennis Brager will be panelist at the 2015 UCLA Annual Tax Controversy Institute. He will be speaking on Comprehensive Review of Assessment Statutes of Limitation. This session will provide an overview of various statutes of limitations, extensions and waivers for income taxes, employment taxes, various penalties including Sections 6672, 6701, the foreign compliance penalties, FBAR […]
I am happy to announce that I will be one of the featured speakers at the 2015 Annual Meeting of the California Tax Bar Conference that is being held from August 4th through August 6th at the Hilton La Jolla Torrey Pines in San Diego. The International Tax Audit & Appeals Including Statute of Limitations […]
International Referral, the world’s largest exclusive network of advisory firms is delighted to introduce Alberto Benshimol of D’Empaire Reyna. Lisa has joined IR as our exclusive Tax(Law) and Mergers & Acquisitions member in Venezuela. Since 1972 D’EMPAIRE REYNA, one of the country’s leading law firms, has been rendering legal services in Venezuela by offering practical and […]
I was quoted in Association For Financial Professionals in an article titled, “FBAR Update: Good News for Treasurers But More Questions Too.” Please click the link below to read more. https://www.bragertaxlaw.com/docs/fbar_update_v2.pdf Brager Tax Law Group
I wrote an article entitled, “IRS Tightens Inventory Rules for Marijuana Businesses,” which was published in the August issue of Marijuana Venture. Please click the link below to read the full article. https://www.bragertaxlaw.com/docs/marijuana_article.pdf Please do not hesitate to contact me if you have any questions. Best regards, Dennis Brager [email protected] 310.208.6200
On July 31, 2015, President Barack Obama signed into a law HR 3236 a highway funding bill. Buried in the Bill is a provision which changes the filing date for Foreign Bank Account Reports (FBARs) to April 15th. Up until now the due date for the FBAR, which must be filed electronically on FinCEN Form […]
Introduction As part of its effort to attract foreign high net worth individuals as well as to attract qualified individuals to relocate and work in the country, either on their own or as part of a group structuring/reorganisation, Cyprus offers some very attractive incentives. These incentives, together with some other advantages that Cyprus has to […]
International Referral, the world’s largest exclusive network of advisory firms is delighted to introduce James Lang of Baynard, McLeod & Lang, P.A. James has joined IR as our exclusive Tax (Law) Member in US – Florida. If you have a requirement in this area, please get in touch with James directly or with the International Referral head office for […]