New Developments in International Taxation
2011 Offshore Voluntary Disclosure Initiative
A special voluntary disclosure initiative has been 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.
Refer also to 2011 Offshore Voluntary Disclosure Initiative.
IRS Realigns and Renames Large Business Division, Enhances Focus on International Tax Administration
IR-2010-88, August 4, 2010 — IRS officials announced today the realignment and renaming of the Large and Mid-Size Business (LMSB) division to Large Business and International (LB&I) division.
International Withholding Designated Tier I
The IRS has designated as a tier I compliance issue "Reporting and Withholding on U.S. Source FDAP Income" under IRC 1441. The focus of compliance improvement will be on withholding agents' obligations to withhold and report to IRS.
U.S./Germany Arbitration of Tax Disputes
The competent authorities of the U.S. and Germany recently signed an arrangement to provide guidance for operating the arbitration procedure that went into force on December 28, 2007. Additionally, the competent authorities prepared guidelines for operating the three-person arbitration boards. Refer to Mandatory Tax Treaty Arbitration.