Wealth & Risk Management Blog

William Byrnes (Texas A&M) tax & compliance articles

FATCA

Practical Compliance Aspects of FATCA and GATCA

 “Another area where Professor Byrnes is making a name for himself as a top authority is the federal tax law known as “FATCA”. The lead author of a 1-volume work released in May, 2013 – Lexis Guide to FATCA Compliance – the book is now in its second edition. One of the hottest topics in all of federal tax, “FATCA” took effect on July 1st  Ray Camiscioli, Esq., Director, Product Strategy & Development for Tax, Accounting and Estates/Elder Law, LexisNexis, Inc.

book coverByrnes’ Lexis Guide to FATCA & CRS Compliance – NEW 2017 edition expanded to two-volume set!

Since the first edition written in Spring of 2012, the industry leading 2,000 page analysis of the FATCA and CRS compliance challenges,  78 chapters by FATCA and CRS contributing experts from over 30 countries.  Besides in-depth, practical analysis, the 2017 edition includes examples, charts, timelines, links to source documents, and compliance analysis pursuant to the IGA and local regulations for many U.S. trading partners and financial centers.   Byrnes’ Lexis Guide to FATCA Compliance, designed from interviews with over 100 financial institutions and professional firms, is a primary reference source for financial institutions and service providers, advisors and government departments.  This treatise also includes in-depth analysis of designing a FATCA internal policy, designing an equivalent form to the W-8, reporting accounts, reporting payments, operational specificity of the mechanisms of information capture, validation for fit for purpose, data management, and exchange by firms and between countries, insights as to the application of FATCA, CRS, and the IGAs within BRIC, SEA and European country chapters.  This fifth edition provides the financial enterprise’s FATCA compliance officer the tools for developing and maintaining a best practices compliance strategy.  No filler of forms and regs – it’s all beef !  See Lexis’ order site and request a copy of the 2017 edition – http://www.lexisnexis.com/store/catalog/booktemplate/productdetail.jsp?pageName=relatedProducts&prodId=prod19190327

A free download FATCA chapter is available at https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2926119

  • Chapter 1 Background and Current Status of FATCA <— free download at SSRN of new edition
  • Chapter 1C Due Diligence Protocol to Identify U.S. Related Accounts Under the Swiss Bank Program
  • Chapter 2 Practical Considerations for Developing a FATCA Compliance Program
  • Chapter 2A FATCA Internal Policy
  • Chapter 2B Project Management for the Financial Institution
  • Chapter 3 FATCA Compliance and Integration of Information Technology
  • Chapter 4 Financial Institution Account Remediation
  • Chapter 4A FATCA Customer Outreach
  • Chapter 5 FBAR and Form 8938 Reporting and List of International Taxpayer IRS Forms
  • Chapter 5A The International Financial System and FATCA
  • Chapter 5B U.S. Offshore Account Enforcement Issues
  • Chapter 6 Determining U.S. Ownership of Foreign Entities
  • Chapter 7 Foreign Financial Institutions
  • Chapter 7A Account reporting under FATCA
  • Chapter 8 Non-Financial Foreign Entities
  • Chapter 9 FATCA and the Offshore Trust Industry
  • Chapter 10 FATCA and the Insurance Industry
  • Chapter 10A FATCA and the Asset Management Industry
  • Chapter 11 Withholding and Qualified Intermediary
  • Chapter 12 FATCA Withholding Compliance
  • Chapter 13 “Withholdable” Payments
  • Chapter 13A Reporting Payments
  • Chapter 14 Determining and Documenting the Payee
  • Chapter 14A W8 Equivalents
  • Chapter 15 Framework of Intergovernmental Agreements
  • Chapter 15A Financial Accounts Excluded by Annex II of an IGA
  • Chapter 16 Analysis of Current Intergovernmental Agreements
  • Chapter 17 European Union Cross Border Information Reporting
  • Chapter 18 The OECD Role in Exchange of Information: The Trace Project, FATCA, and Beyond
  • Chapter 19 Germany
  • Chapter 20 Ireland
  • Chapter 21 Japan
  • Chapter 22 Mexico
  • Chapter 23 Switzerland
  • Chapter 24 United Kingdom
  • Chapter 25 Brazil
  • Chapter 26 British Virgin Islands
  • Chapter 27 Canada
  • Chapter 28 Spain
  • Chapter 29 China
  • Chapter 30 Netherlands
  • Chapter 31 Luxembourg
  • Chapter 32 Russia
  • Chapter 33 Turkey
  • Chapter 34 India
  • Chapter 35 Argentina
  • Chapter 36 Aruba
  • Chapter 37 Australia
  • Chapter 38 Bermuda
  • Chapter 39 Colombia
  • Chapter 40 Cyprus
  • Chapter 41 Hong Kong
  • Chapter 42 Macau
  • Chapter 43 Portugal
  • Chapter 44 South Africa
  • Chapter 45 France
  • Chapter 46 Gibraltar
  • Chapter 47 Guernsey
  • Chapter 48 Italy
  • Chapter 49 Korea
  • Chapter 50 New Zealand
  • Chapter 51 Suriname
  • Chapter 52 Singapore
  • Chapter 53 Brunei
  • Chapter 54 Cambodia
  • Chapter 55 Myanmar
  • Chapter 56 Pakistan
  • Chapter 57 Indonesia
  • Chapter 58 Pakistan
  • Chapter 59 Philippines
  • Chapter 60 Vietnam
  • Chapter 61 Cayman Islands
  • Chapter 62 Norway
  • Chapter 63 Greece
  • Chapter 64 Malaysia
  • Chapter 65 Monaco
  • Chapter 66 Thailand

FATCA Experts Selected for the Lexis’ Guide

Contributing FATCA Authors and Expert Practitioners

Theodore C. Ahlgren, Esq.

Ted Ahlgren concentrates his practice on international tax, trust, and estate planning. He has advised numerous U.S. and non-U.S. financial institutions, corporations, high net worth individuals, and their advisors on a variety of U.S. federal income, transfer, and withholding tax issues and has represented individuals and financial institutions in audits and voluntary disclosures. He participated in the submission of comments to Treasury and the IRS on the proposed FATCA regulations, and has written and spoken extensively on FATCA and other topics of relevance to international tax and estate planning. He may be contacted at tahlgren@gmail.com. Contributions include chapter 7: Foreign Financial Institutions.

Michael Alliston, Esq.

Michael Alliston is a solicitor in the London office of Herbert Smith Freehills LLP. He advises on a range of corporate tax matters including mergers and acquisitions, corporate reorganizations, general finance and capital markets transactions. He also has particular experience in real estate and investment fund transactions and much of his work involves a cross-border element. Michael regularly advises clients on the transactional implications of FATCA from a UK law perspective and presents externally on the subject. He may be contacted at Michael.Alliston@hsf.com. Contribution includes chapter 24: U.K.-U.S. Intergovernmental Agreement and Its Implementation.

Devang Ambavi

Devang Ambavi is Associate Director at PricewaterhouseCoopers Pvt. Ltd, India (PwC). He has over ten years of experience in advising clients in multidisciplinary areas including international tax, domestic tax, exchange control and regulatory matters. He has worked extensively and advising and assisting Indian financial institutions to comply with the information reporting requirements under FATCA and CRS. More recently, he was on a two year secondment to PwC New York where he advised US based Funds on global structuring and international tax issues on a cross-jurisdictional basis. He also advised private equity, hedge and special opportunity funds on their global structuring issues and worked closely with the global network of PwC’s offices to develop tax efficient structures for a variety of investments by funds in Europe, Asia and Latin America.  He may be contacted at devang.ambavi@in.pwc.com. Contribution includes chapter 34: Exchange of Tax Information and Impact of FATCA for India.

Laila Arstall, Esq.

Laila Arstall is an Advocate of the Courts of Guernsey and a Solicitor of the Supreme Court of England and Wales (currently non-practicing). She is Senior Associate at Carey Olsen, Guernsey and was previously an associate in the Private Client Department of Allen & Overy in London where she specialized in international and U.K. estate and tax planning. Since moving to Guernsey from Singapore, Laila has developed considerable experience in matters of taxation under Guernsey law and practice, including in relation to the EU Savings Directive as implemented in Guernsey and the various bilateral Tax Information Exchange Agreements to which Guernsey is a party. Laila is a regular member of Working Parties established by industry and by the States of Guernsey Income Tax Office to consider matters of taxation and tax compliance. In 2012 Laila was asked to draft amendments to Guernsey’s tax law in response to developments in the UK’s treatment of offshore pensions. Laila is currently a member of the Statement of Practice Working Group and the FATCA Working Group, established by the States of Guernsey’s Income Tax Office to assist with the development of guidance on matters of tax and tax compliance. Laila may be contacted at laila.arstall@careyolsen.com. Contribution includes chapter 47: The Impact of FATCA on Exchange of Tax Information for Guernsey.

Sanam Bhatia-Atkins CA.

Specializing in financial services at Deloitte Singapore, Sanam has a wide range of experience in tax advisory projects across Asia Pacific and in the UK.  Sanam has a key focus on FATCA and provides advice to financial institutions across South East Asia.  She is currently closely monitoring CRS developments in the region.  She may be contacted at sabhatia@deloitte.com.  Contributions include chapter XX: Singapore, chapter XX: Indonesia and chapter XX: Brunei.

Frankie Barbour, Esq.

Frankie Barbour is a solicitor at King & Wood Mallesons. She is a Barrister and Solicitor of the Supreme Court of Victoria and the High Court of Australia, specializing in income tax. Ms. Barbour is a member of the Law Institute of Victoria. She holds a Bachelor of Creative Arts and Laws (Honours) from the University of Melbourne. She may be contacted at frankie.barbour@ au.kwm.com. Contribution includes chapter 36: The Australia-U.S. Intergovernmental Agreement and its Implementation and chapter 18A: The Common Reporting Standard.

Jason Barnes, Esq.

Jason Barnes is a Special Counsel of King & Wood Mallesons.  . He is a Barrister and Solicitor of the Supreme Court of Victoria and the High Court of Australia. He specializes in income tax and advises local and international clients in the financial services and resources sectors, focusing principally on the tax aspects of capital management, financing and cross-border transactions. Mr. Barnes is a member of the Law Institute of Victoria and has a Chartered Tax Advisor designation with The Tax Institute. He holds Honours Degrees of Bachelor of Commerce and of Laws from Monash University and a LL.M. from the University of Melbourne. He may be contacted at jason.barnes@ au.kwm.com. Contribution includes chapter 36: The Australia-U.S. Intergovernmental Agreement and its Implementation and chapter 18A: The Common Reporting Standard.

Tom Barnes, Esq.

Tom Barnes is a senior associate at DLA Piper (New Zealand).  He is a Barrister and Solicitor of the High Court of New Zealand and focuses his practice on funds management, financial services and related regulatory compliance.  Mr Barnes is a Member of the Law Society of New Zealand and holds a Bachelor of Laws from Victoria University of Wellington.  He may be contacted at tom.barnes@dlapiper.co.nz.  Contributions include Chapter XX: New Zealand-U.S. Intergovernmental Agreement and Its Implementation.

Maarten de Bruin, Esq.

Maarten de Bruin advises on domestic and international tax aspects of commercial and (structured) finance transactions for Stibbe Simont. Maarten joined Stibbe’s tax department in 1989 and moved to the New York office in 1993 where he became partner in 1997. While in New York he graduated from New York University (tax LLM) and spent 6 months in the tax department of Cravath Swaine & Moore. He returned to the Amsterdam office of Stibbe in 1999 where he focused on clients in the industrial and real estate sector. His clients include Accor, Tata, APG and Super de Boer. He may be contacted at maarten.deBruin@stibbe.com. Contribution includes chapter 30: Exchange of Tax Information and Impact of FATCA for the Netherlands.

Nina Aleksandrovna Boer, Esq.

Nina Aleksandrovna Boer has since 2013 held the position of director of “Semenyako, Golubok and Partners” Law offices in St. Petersburg. Nina Aleksandrovna Boer is an acknowledged expert in bankruptcy law and in taxation of foreign investment, with several publications in these areas. She graduated from the State University of Saint Petersburg. She may be contacted at nb@absgp.ru. Her contribution is chapter 32: Exchange of Tax Information and the Impact of FATCA for Russia.

Laurie Hatten-Boyd, Esq.

Laurie Hatten-Boyd is a Principal in KPMG’s Washington National Tax Practice and heads up the firm’s Tax Information Reporting & Withholding group. Prior to joining KPMG, Laurie was an Attorney-Advisor with the IRS Office of Associate Chief Counsel (International), where she worked exclusively with the section 1441 withholding regime, including drafting the amendments to the section 1441 regulations, the qualified intermediary agreement, the qualified intermediary audit guidelines, and the proposed withholding agreements for foreign partnerships and foreign trusts. Laurie is a frequent speaker on foreign withholding issues and has authored articles appearing in the International Tax Review, International Law Journal, and The Tax Lawyer. She is a member of the Washington State Bar Association. Laurie received a JD degree (magna cum laude) from Gonzaga University and an LL.M. in Tax (with distinction) from Georgetown University Law Center.

Laurie routinely engages in a wide range of withholding tax advisory services to assist both financial and non-financial institutions in complying with their U.S. tax information reporting and withholding requirements. She was acknowledged as one of 10 prominent people in tax nominated by Tax Notes Today for 2011 “Person of the Year,” earning this important recognition through her intense efforts to help companies understand and respond to the potential implications of FATCA’s far-reaching tax reporting and withholding requirements. She may be contacted at lhattenboyd@kpmg.com. Contribution includes chapter 14: Documenting for FATCA.

Amanda Castellano, Esq.

Amanda Castellano, an attorney working on tax, business, nonprofit and estate planning matters spent three years as an auditor with the Internal Revenue Service. She is currently a tax consultant based in Portland, Oregon. She graduated summa cum laude from Thomas Jefferson School of Law, where she served as Chief Notes Editor on the Thomas Jefferson Law Review. She may be contacted at LBNConsultingServices@gmail.com. Contribution includes chapter 1: Introduction (Accidental American).

Jim Calvin, CPA.

Jim Calvin is the Global Tax Managing Director of the asset management practice at Deloitte. He has over 24 years of experience at Deloitte. He specializes in information reporting and the taxation of investment funds and security transactions. He is the Asia Pacific Regional Leader for the global implementation of the Foreign Account Tax Compliance Act (FATCA) and the OECD Common Reporting Standard provisions. He is the author of Regulated Investment Companies (RIA), and was the editor of the Journal of Taxation of Investments.  He may be contacted at jimcalvin@deloitte.com.  Contributions include chapters for the Exchange of Tax Information and Impact of FATCA for Singapore and also for other Asian countries.

Vaughan Carter, Esq.

Vaughan Carter is a Partner at Etienne Blake, a Cayman Islands law firm, where he specializes in Government, Regulatory and Public Law and, amongst various academic affiliations; he is an Honorary Knowledge Exchange Associate in the Small Jurisdictions Service of the School of Law at Oxford Brookes University in the United Kingdom.  The author is grateful for the assistance of the Director of the Department of International Tax Cooperation in the Cayman Islands, Duncan Nicol, whose presentation inspired this title; and of Simone Proctor, a former colleague and a continuing source of expertise and advice on FATCA and related matters.  He may be contacted at vaughan.carter@etienneblake.com.  Is contribution includes chapter XX: The Cayman Islands, FATCA and the Automatic Exchange of Tax Information: Not the End; Merely the End of the Beginning.

Dr. Luzius Cavelti, Esq.

Luzius obtained his law degree from the University of Fribourg, Switzerland. He is qualified as certified tax expert (specialization in international tax) and holds an LL.M. degree from the Columbia School of Law and Ph.D. in law from the University of Bern, Switzerland. Luzius is admitted to the bar in Zurich and works as associate at Tappolet & Partner in Zurich. Luzius is specialized in international and domestic tax law. He may be contacted at luzi.cavelti@tappolet-partner.ch. Contribution includes chapter 23: Switzerland-U.S. Intergovernmental Agreement and Its Implementation.

Diny Chang

Diny Chang is currently pursuing international tax law and her Juris Doctorate at Texas A&M University School of Law and holds a degree in Economics from Brigham Young University. She is fluent in Mandarin, including both simplified and traditional characters, editing and translating World Book Encyclopedia.  Her career experience includes sourcing and negotiating with cross border (China) vendors, month-on-month tripling of the sales goal for a public company (Nu Skin), and operations for the 2010 World Expo (Shanghai) – USA Pavilion.  She currently serves as the liaison of Bloomberg Law for Texas A&M Law. She may be contacted at dcatkinson@tamu.edu.  Contributions includes assistance for Haydon Perryman for chapter 2B: FATCA Project Management for the Financial Institution, as well as on chapter 29: China and chapter 40: Colombia.

Peter Cotorceanu, Esq.

Peter Cotorceanu is CEO and Founder of GATCA & Trusts Compliance Associates LLC (G&TCA), a consulting firm on FATCA and compliance for the fiduciary industry.  Mr. Cotorceanu is Of Counsel  to the Zurich, Switzerland office of Anaford AG. Before returning to private practice, Peter was the Head of Product Management for Trusts and Foundations at UBS AG in Zurich. He was previously UBS’s Head of Wealth Structuring Consulting for UHNW clients in Zurich. While at UBS, Peter was responsible for implementing UBS’s FATCA compliance for trusts, foundations, and other fiduciary structures. Before joining UBS, Peter practiced law for over 20 years, both in Switzerland and the U.S., most recently at Baker & McKenzie Zurich. Peter was also a law professor for a number of years at Washburn University School of Law, Topeka, Kansas and (as an adjunct) at the Marshall-Wythe School of Law, College of William and Mary, in Williamsburg, Virginia. Peter is a former member of the Board of Governors of Virginia State Bar’s Trusts and Estates Section, as well as the Kansas Judicial Council’s Probate Advisory Committee and Estate Tax Advisory Sub-Committee. Peter is a New Zealand barrister and solicitor and an attorney licensed in Maryland and Virginia. He may be contacted at peter.cotorceanu@gatcaandtrusts.com. Contribution includes chapter 9: FATCA and the Offshore Trust Industry.

Bruno Da Silva, LL.M.

Bruno da Silva works at Loyens & Loeff, European Direct Tax Law team, is a tax treaty adviser for the Macau special administrative region of the People’s Republic of China, and is also a researcher at the Amsterdam Centre for Tax Law of the University of Amsterdam. He lectures at different institutions such as the University of Leiden, University of Amsterdam, International Bureau of Fiscal Documentation (IBFD), Universidade Católica Portuguesa and IBDT (Brazil). He obtained an LL.M. in International Tax Law and he is currently pursuing his Ph.D. He may be contacted at bruno.silva@loyensloeff.com. Contribution includes chapter 17: European Union Cross Border Information Reporting; and chapter 18: The OECD Role On Exchange Of Information: The TRACE Project, FATCA, and Beyond.

Alice Deng, Esq.

Alice Deng is an Associate at Greenwoods & Herbert Smith Freehills Pty Limited. Alice holds Degrees of Bachelor of Commerce and of Laws from the University of Sydney. Alice specializes in income tax and advises local and international clients in, among others, the real estate sector. She may be contacted at alice.deng@greenwoods.com.au. Contribution includes chapter 36: The Australia-U.S. Intergovernmental Agreement and its Implementation.

Prof. J. Richard Duke, Esq.

Richard Duke, attorney, is a member of the Alabama and the Florida Bar, specializing over forty years in income and estate tax planning and compliance, as well as asset protection, for high net wealth individuals. He served as Counsel to the Ludwig von Mises Institute for Austrian Economics 1983–1989 and a Fellow and Honorary Legal Scholar of the International Academy of Tax Advisors. Over his career he has served on numerous American Bar Association Committees and written many articles for legal and financial publications, several books, and was named to the list of “Top 100 Attorneys” in the U.S., Worth magazine, December 2005–2008. He is a Professor of Law of the LL.M. International Tax Program of Thomas Jefferson School of Law, San Diego, California and was an Adjunct Professor of Law at the Cumberland School of Law of Samford University International for Tax and Asset Protection Planning from 1983–1999. He may be contacted at richard@assetlaw.com. Previous contribution included chapter 11: Withholding and Qualified Intermediary Reporting, chapter 12: Withholding and FATCA, chapter 13: “Withholdable” Payments, and chapter 14: Determining and Documenting the Payee.

Dr. Daniel N. Erasmus, Esq.

Dr. Daniel N. Erasmus is an adjunct professor of international tax at Thomas Jefferson School of Law, and lectures extensively on international tax matters in Africa. He practices international tax in the U.S. and throughout Africa from offices based in West Palm Beach, FL, U.S.A. He has associate offices in Johannesburg, Cape Town, Port Elizabeth, Lagos (Nigeria) and Mauritius. He has authored and co-authored seven textbooks on tax (exchange control, capital gains, VAT, SA tax summaries and tax risk management and tax administrative law). He may be contacted at daniel@taxriskmanagement.com. Contribution includes chapter 44: Exchange of Tax Information and Impact of FATCA for South Africa.

Hanneke Farrand, Esq.

Hanneke Farrand is a director in the tax department of ENSAfrica, based in Cape Town, South Africa, specializing in local and international employment and individual tax, in particular inbound and outbound expatriate tax issues, advising companies on local employees’ tax matters, which include various aspects of employee incentive schemes. She is recognized by the publication Best Lawyers 2013, 2012—Tax (South Africa). Hanneke co-authored the South African Country Chapter in the Employment Law Review 2010, as well as the South African Country Chapter in Getting the Deal Through: Labour and Employment 2007, 2008 and 2009. She may be contacted at hfarrand@ensafrica.com. Contribution includes chapter 44: Exchange of Tax Information and Impact of FATCA for South Africa.

Diogo de Andrade Figueiredo, LL.M.

Diogo de Andrade Figueiredo is partner at Souza, Schneider, Pugliese e Sztokfisz in charge of the advisory and tax planning areas. He is member of the academic committee of the specialization course in International Taxation at IBDT (Brazil), where he also lectures. He holds a law degree from Pontifical Catholic University of Sao Paulo, a specialization degree in Tax Law from IBET (Brazil) and Economics and Corporate Law from FGV (Brazil), and a LL.M. in International Taxation from University of Florida, Levin College of Law. He may be contacted at diogo.figueiredo@souzaschneider.com.br. Contributions include chapter 25: Exchange of Tax Information and the Impact of FATCA for Brazil.

Diego Fraga, Esq.

Diego Fraga is a partner in RCTZZ Lawyers (Argentina) where he advises clients on corporate tax law in general and on international tax law. He graduated in law from the University of Buenos Aires and he has a Tax Law Specialist degree from Universidad Austral (Argentina). He is Postgraduate Professor in Tax Law at Universidad Austral (Buenos Aires) and Finance & Tax Law Professor at Universidad de la Marina Mercante (Buenos Aires). He began his career in 1998 at the National Tax Directorate of the Ministry of Economy and left public service in 2008. He is the author of more than 60 Tax Law articles and of the book Treatise on Tax information (Thomson/Reuters). He may be contacted at fraga@rctzz.com.ar. Contribution includes chapter 38: Exchange of Tax Information and Impact of FATCA for Argentina.

Umurcan Gago, Esq.

Umurcan Gago is a partner of PwC Turkey as well as GSG Attorneys at Law. He is a member of the Istanbul Bar and an Independent Chartered Accountant and Financial Advisor. He has LL.M degrees from Columbia School of Law and Yeditepe Hukuk Fakültesi. Umurcan specializes in cross border financial transactions, financial structures/products, conventional and structured financial products, investment banking products, international tax planning, securities law related matters, and financial structuring. He may be contacted at umurcan.gago@tr.pwc.com or Umurcan.gago@gsghukuk.com. Contribution includes chapter 33: Exchange of Tax Information and the Impact of FATCA for Turkey.

Dr. F. Alfredo García

Dr. F. Alfredo García is professor of Financial and Tax Law at the University of Valencia and Jean Monnet Chair of EU Law and Taxation. He is a professor of European Taxation at Thomas Jefferson School of Law in California, and has been visiting professor at the Universities of London, Harvard, Leiden, Leuven, Bergamo and Georgetown. He may be contacted at alfredo.garcia@uv.es. Previous contribution included chapter 28: Spain-U.S. Intergovernmental Agreement and its Implementation.

Dr. Valcir Gassen

Dr. Valcir Gassen is a Professor of Federal University of Brasilia (UnB), participating with the support CAPES Foundation, Ministry of Education of Brazil. His hold a law degree from the University of Northwest of State of Rio Grande do Sul; an LL.M. from the Federal University of Santa Catarina; Ph.D. from the Federal University of Santa Catarina and Post-doctoral research from the University of Alicante, Spain. He coordinates since 2009 the Research Group in State, Constitution and Tax Law, with undergraduate and graduate students in UnB. He may be contacted at vgassen@gmail.com. Contribution includes chapter 25: Exchange of Tax Information and the Impact of FATCA for Brazil.

Alan Winston Granwell, Esq.

Alan Granwell has practiced in the area of international taxation for over 40 years. He is of counsel to Sharp Partners PA, resident in their Washington, DC office. From 1981 through 1984, Mr. Granwell was the International Tax Counsel and Director, Office of International Tax Affairs at the US Department of the Treasury.  In that capacity, Mr. Granwell was the senior international tax advisor at the Treasury Department and was responsible for advising the Assistant Secretary for Tax Policy on legislation, regulations and administrative matters involving international taxation and directing the US tax treaty program.  In the past few years, Mr. Granwell has been active in the area of the Swiss Bank Program and advising on all aspects of FATCA and intergovernmental agreements.  Mr. Granwell’s practice also encompasses representing multinational corporations on cross-border planning and controversies, and advising high-net-worth individuals on cross-border tax planning and structuring, to include foreign persons becoming U.S. persons and U.S. persons moving offshore or expatriating.  Mr. Granwell also conducts an active administrative practice, regularly representing clients before the Internal Revenue Service and the US Treasury Department (including negotiating advance pricing agreements, conducting competent authority proceedings).

Maria Paulina Avila Gomez, Esq.

Maria Paulina Avila Gomez is a Colombian attorney with more than twenty years of ample experience working in taxes and legal services with KPMG Impuestos y Servicios Legales Ltda, Ernst & Young Ltda, and in the finance department of Citibank Colombia S.A. She has been very involved locally in the understanding, implementation and compliance of the U.S. federal tax law known as FATCA, since it was enacted in year 2010. She has participated in several local Committees regarding FATCA, with the Colombian Banks Association (Asobancaria) and with the Colombian Tax Authority (DIAN), and she has created and leads Citibank’s FATCA Primary Committee. She has participated in various local and foreign publications, among others: Doing Business, EY Global Employment Solutions, KPMG Legal Bulletin, Portafolio—Consultorio Tributario. She has important tax law teaching experience as a Professor in several Colombian Universities at graduate and undergraduate programs, and she has been invited as a Special Speaker in different seminars regarding tax matters. She holds a Juris Doctor (JD) Degree from Universidad del Rosario, a post-graduate degrees in Financial Law and in Tax Law from Universidad del Rosario, and post-graduate diplomas of History and of Philosophy from Universidad Externado de Colombia associated with the Universidad Nacional de Colombia. She may be contacted at mp_avila@hotmail.com. Contributions include chapter 40: Colombia-U.S. Intergovernmental Agreement and Its Implementation.

Lincoln D. Gomez, Esq. LL.M.

Lincoln D. Gomez is an attorney-at-law with Gomez & Bikker in Aruba. He specializes in aircraft registrations, related financing transactions and tax structuring. He obtained his LL.M. in International Taxation & Financial Services from Thomas Jefferson School of Law. He has a law degree from the Universiteit van Aruba. He recently finished a two year term as President of the Aruba Bar Association. He may be contacted at lincoln@gobiklaw.com. Contribution includes chapter 35: Exchange of Tax Information and Impact of FATCA for Aruba.

Professor Richard K. Gordon

Richard K. Gordon is Professor of Law at Case Western Reserve University and Director of Financial Integrity Programs at the School of Professional Studies, Brown University. Previously he served as Senior Counsel and Senior Financial Sector Expert at the International Monetary Fund, and as Deputy Director of the International Tax Program at Harvard University. He has written much on tax and tax administration as well as on financial integrity compliance. He received his BA from Yale and his JD from Harvard.

Denise M. Hintzke, Esq.

Denise M. Hintzke is the Global U.S. Tax Leader of Deloitte’s Foreign Account Tax Compliance Initiative. In this role, she works closely with the U.S. Tax Information and Reporting Practice as well as the Deloitte Member Firms as the Firms deploy cross-functional talent to the global market place in response to the demanding requirements of the provisions of the U.S. Foreign Account Tax Compliance Act.  She may be contacted at dhintzke@deloitte.com.  Contributions include chapter 6: Specified Foreign Financial Asset Reporting, chapter 11: Withholding and Qualified Intermediary, and chapter 13: Withholdable Payments Under FATCA.

Véronique Hoffeld, Esq.

Véronique Hoffeld, attorney-at-law, is a member of the Management Committee of Loyens & Loeff Luxembourg and heads the Luxembourg Commercial and Litigation department. She can be considered as a generalist lawyer, whose activities cover matters in the areas of commercial law (negotiation of contracts), litigation and arbitration, bankruptcy & restructuring, IP law, real estate law, environment law, E-commerce and new technologies. Véronique is also occasionally involved in maritime and administrative law matters. Prior to joining Loyens & Loeff Luxembourg, Véronique worked for more than 10 years in another important Luxembourg law firm at which she was made partner in 2003. Véronique is a member of the Luxembourg Bar since 1996. She may be contacted at veronique.hoffeld@loyensloeff.com. Contributions include chapter 31: Exchange of Tax Information and Impact of FATCA for Luxembourg.

Rob. H. Holt, Esq.

Rob H. Holt is a practicing attorney of thirty years licensed in New York and Texas representing real estate investment companies, university professors, and a variety of other business owners in the formation of their entities, business contracts, and distribution and channel documentation. He is currently completing his LL.M. in Taxation from Thomas Jefferson School of Law. Rob and his wife of 29 years live in College Station/Bryan, Texas. He is an avid, amateur ballroom dancer and loves the waltz, foxtrot, and tango. He may be contacted at rhh@robhholt.com. Past contribution includes chapter 7: Foreign Financial Institutions.

Jordan Issaakidis, Esq.

Jordan Issaakidis is an assistant manager in the financial services tax practice at Deloitte Singapore. He specializes in asset management, anti-money laundering and international taxation. He has advisory experience across Asia Pacific.  He may be contacted at jissaakidis@deloitte.com.  Contributions include chapter XX:Philippines, chapter XX:Laos and chapter XX:Vietnam.

Richard Kando, CPA

Richard Kando, a Certified Public Accountant (New York) is a Director at Navigant Consulting. Richard specializes in forensic accounting and compliance matters relating to Government investigations, anti-money laundering and the Foreign Account Tax Compliance Act (“FATCA”). Richard is a leader of Navigant’s FATCA task force. Previously, Richard served as a Special Agent with the IRS Criminal Investigation Division where he received the U.S. Department of Justice—Tax Division Assistant Attorney General’s Special Contribution Award. He may be contacted at richard.kando@navigant.com. Contribution includes chapter 2: Practical Considerations for Developing a FATCA Compliance Program.

Stefan Kaestli

Stefan Kaestli is the FATCA Responsible Officer for a Swiss FFI including its affiliated group companies. Before joining his current employer, he worked as a management consultant with a global business and technology consultancy where he assisted a global top 10 bank implement FATCA. Stefan gained more than a decade of experience in private, corporate and investment banking, where much of his work involved compliance, regulatory, tax and cross-border elements. Stefan is the author of several FATCA relevant articles. He holds a B.B.A. from University of Applied Sciences St. Gallen (CH), an M.A. in International Business and Management from Bradford University (UK), an M.A. in Management and Marketing from Kozminski University (PL), and an M.B.A. (joint degree) from Kozminski University (PL)/Otto Beisheim School of Management WHU (DE)/Leipzig Graduate School of Management HHL (DE). He may be contacted at stefan.kaestli@kaestli.name. Contribution includes chapter 13A: Analysis of Reportable Payments Pursuant To FATCA, and chapter 7A: Information Reporting.

Frank van Kuijk, Esq.

Frank van Kuijk, tax adviser, is a member of the Tax practice group. He specializes in international tax law, predominantly Luxembourg-oriented. He advises a wide range of multinationals and private equity funds with respect to their tax structure in Luxembourg. His advice mainly relates to acquisitions, project financing, structured finance, securitizations, corporate reorganizations and IP. He worked three years at the Rotterdam office, two years at the Luxembourg office and two-and-a-half years at the London office. Frank is a member of the International Fiscal Association, Luxembourg branch (IFA) and the Dutch Association of Tax Advisers. He may be contacted at frank.van.kuijk@loyensloeff.com. Contributions include chapter 31: Exchange of Tax Information and Impact of FATCA for Luxembourg.

Denis Kleinfeld, Esq., CPA.

Denis Kleinfeld is Of Counsel to Fuerst Ittleman David & Joseph, PL, in Miami, Florida,  an International Tax Professor of Texas A&M University School of Law, and a Professor of Law of the LL.M. International Tax Program of Thomas Jefferson School of Law, San Diego, California. The author of chapters in prominent legal publications, he has written extensively in professional and general circulation magazines and publications on a wide variety of tax, insurance, estate planning, treaty planning, domestic and international asset protection, and investment issues as well as observations on relevant political, social and economic issues. Mr. Kleinfeld is the founder of, and now serves as co-chairman for, the Florida Annual Wealth Protection Conference and is a speaker at a wide variety of professional conferences, seminars, and symposiums in the United States and around the world. After obtaining his B.S. degree in Accountancy from the University of Illinois in 1967 and obtaining his license as a Certified Public Accountant, Mr. Kleinfeld enrolled at the Loyola University of Chicago School of Law, graduating in 1970. He was admitted to the Illinois Bar in 1970 and was employed as an attorney with the Internal Revenue Service in the Estate and Gift Tax Division for four years before going into private practice. Mr. Kleinfeld has been a member of the Florida Bar since 1983, and is also a member of the Florida Institute of Certified Public Accountants, the American Bar Association, and the American Institute of Certified Public Accountants. He may be contacted at deniskleinfeld@kleinfeld.com. Contribution includes chapter 1: Introduction and chapter 5: FBAR & 8938 FATCA Reporting.

Erin E. Kragh, Esq.

Erin is a Tax Manager in the NY Financial Services Practice of KPMG LLP. She joined KPMG in 2011 and currently practices U.S. information reporting and withholding, including compliance related to the Foreign Account Tax Compliance Act (“FATCA”) for U.S. withholding agents and foreign financial institutions. She co-authored a publication for Bloomberg BNA regarding the IRS FATCA registration portal, served as a contributing author on KPMG International Bank Tax News Flash newsletters, and has acted as a presenter for webcasts and trainings. Prior to joining KPMG, Erin completed a clerkship with the Tax Court of New Jersey. She is a graduate of Rutgers School of Law-Newark (J.D.) and the University of Wisconsin-Madison (B.A.). She may be contacted at ekragh@kpmg.com. Contribution includes chapter 14: Documenting for FATCA.

Shinjini Kumar

Shinjini Kumar is a partner of PricewaterhouseCoopers Pvt. Ltd, India (PwC). She is the Sector leader for Banking and Capital Markets and also heads Financial Services regulatory practice at PwC India. Prior to joining PwC in 2010, Shinjini has held senior positions at the Reserve Bank of India (RBI) and Bank of America-Merrill Lynch. Her vast experience with the regulator and industry gives her the distinctive opportunity to engage with the industry, media and policy makers on important issues affecting the industry. She may be contacted at shinjini.kumar@in.pwc.com. Contribution includes chapter 34: Exchange of Tax Information and Impact of FATCA for India.

Priscilla Lachman

Priscilla Lachman is the Head of the International Fiscal Affairs division at the Tax & Customs Administration, Ministry of Finance, Government of Suriname.  She is also a correspondent to the Inter-American Center of Tax Administrations for the government of Suriname. Before she joined the public service sector, she was a tax advisor in the Netherlands of RSM Niehe Lancée Kooij, Ernst & Young, and an international tax trainnee of Loyens & Loeff.  She holds an LL.M. (Leiden) and Bachelor of Tax Law (Leiden). Ms. Lachman may be contacted at prislach@hotmail.com.  Contribution includes chapter XX: Exchange of Tax Information for Suriname.

Louis-Philippe Landry, CA.

Louis-Philippe Landry started his career as a chartered accountant in assurance and financial accounting before specializing in taxation.  He completed his “In Depth Tax Course” given by the Canadian Institute of Chartered Accountants in 2012.  Since 2008, he gained valuable experience working in large public accounting firms before joining BMO Nesbitt Burns as a wealth management consultant.  Louis-Philippe has been advising family business owners and private companies on financial accounting, Canadian and US taxation, succession and estate planning.   He may be contacted at LouisPhilippe.Landry@bmo.com. Contribution includes chapter 27: Exchange of Tax Information and Impact of FATCA for Canada.

Marina Lee, Esq.

Marina Lee is a lawyer at Souza, Schneider, Pugliese e Sztokfisz. She holds a law degree from University of Sao Paulo (USP), a specialization degree in Tax Law from Fundação Getúlio Vargas (FGV) and International Taxation at IBDT (Brazil). She may be contacted at marina.lee@souzaschneider.com.br. Contributions include chapter 25: Exchange of Tax Information and the Impact of FATCA for Brazil.

Mathias M. Link, Esq., LL.M.

Mathias Link is a counsel in the Frankfurt office of Hengeler Mueller. He is qualified as German attorney-at-law and tax consultant, holds an LL.M. degree from Columbia University and is also admitted to the New York bar. He advises corporate clients, banks and financial services institutions on a variety of tax matters including mergers and acquisitions, reorganizations, finance and capital markets transactions. He has particular expertise in the structuring of private equity, real estate and investment fund transactions and his main focus is on international tax aspects. Mathias regularly advises clients on the implications of FATCA from a German law perspective. He may be contacted at Mathias.Link@hengeler.com. Contribution includes chapter 19: Germany-U.S. Intergovernmental Agreement and Its Implementation.

Jinghua Liu, Esq.

Jinghua Liu is a partner in the Tax group at Baker & McKenzie and is based in the Beijing office. She heads the tax dispute resolution practice in China. She joined Baker & McKenzie in 2004 and has been practicing China tax law since then. She is a frequent speaker at international tax conferences on PRC taxation and international tax planning, and authored and co-authored various articles in leading tax publications. Chambers Asia Pacific lists her as one of the recommended lawyers for tax in 2011 and 2012. She may be contacted at jinghua.liu@bakermckenzie.com. Contribution includes chapter 29: Exchange of Tax Information and Impact of FATCA for China.

Jeffrey Locke, Esq.

Jeffrey Locke is Director at Navigant Consulting. At Navigant, he is a leader of the FATCA Task Force and has drafted numerous white papers and articles concerning the practical implementation of FATCA. Prior to joining Navigant, he served as an assistant New York state attorney general in the Criminal Prosecutions Bureau, worked in the prosecutor’s office for the United Nations in Kosovo and was an assistant public defender in Philadelphia. He received his law degree from Columbia Law School. Mr. Locke recently contributed a chapter to the book “International Prosecutors” published by Oxford University Press. He may be contacted at jeffrey.locke@navigant.com. Contribution includes chapter 2: Practical Considerations for Developing a FATCA Compliance Program.

Josh Lom

Josh works at Herbert Smith Freehills LLP having graduated from Oxford University. He may be contacted at josh.lom@hsf.com. Contributions include chapter 24: UK-U.S. Intergovernmental Agreement and Its Implementation.

Scott D. Michel, Esq.

Scott D. Michel is a Member of Caplin & Drysdale, has been with the firm since 1981, and served as the firm’s President from 2007 to 2015.  He advises clients on tax compliance issues, including criminal tax investigations, sensitive civil audits, and voluntary disclosures.  Currently he represents numerous clients worldwide in matters arising from the IRS and Justice Department’s crackdown on unreported foreign assets and accounts, and a number of Swiss banks participating in the Department of Justice Swiss Bank Program.  Mr. Michel is also an Adjunct Professor of Law at the University of Miami School of Law Graduate Program in Taxation and a Fellow of the American College of Tax Counsel.  He may be contacted at smichel@capdale.com.  His contribution is Chapter 1B U.S. Offshore Account Enforcement Issues.

Jason R. Miller

Jason R. Miller recently spent the summer as a stagier at PwC Istanbul working with Umurcan Gago to author several chapters on Turkey for Lexis publications. He will graduate in 2014 from Thomas Jefferson School of Law with his Juris Doctorate specializing in Global Legal Studies and Business Law. Jason has a BS in Business Administration from California Polytechnic State University, San Luis Obispo, with a concentration in Human Resources. He has contributed to publications for LexisNexis and Wolters Kluwer, including chapters on Company Law, AML, FATCA, and Foreign Tax and Trade Briefs. Jason is an Editor of the Thomas Jefferson Law Review. He may be contacted at jasonryanmiller@gmail.com. Contribution includes chapter 33: Exchange of Tax Information and the Impact of FATCA for Turkey.

Kelley C. Miller, Esq.

Kelley is an associate in Reed Smith’s Tax Group. Significant aspects of her practice involve complex federal tax controversies, state and federal tax issues involving closely held entities, state tax planning and litigation and tax planning issues involving E-Commerce, cloud computing, and state nexus. Kelley regularly advises clients on federal and state tax planning opportunities and she has experience representing clients in civil and criminal tax matters before state tribunals and administrative agencies, state courts, and federal courts. Kelley routinely represents clients before the Internal Revenue Service. She has written and spoken widely on numerous federal and state tax topics for clients representing a broad spectrum of industries, including exempt organizations. She may be contacted at kmiller@reedsmith.com. Her contribution includes chapter 12: FATCA Withholding Compliance.

Dr. Robert J. Munro, Esq.

Dr. Robert Munro is the author of 35 published books including Lexis’ three volume Tax Havens of the World, two volume Foreign Tax & Trade Briefs, and Money Laundering, Asset Forfeiture and Recovery, and Compliance—A Global Guide. He is a Professor of the International Tax & Financial Services Graduate Program of Thomas Jefferson School of Law, San Diego, California. A former Law Librarian at University of Florida College of Law, Dr. Munro was the Director of the Center for International Financial Crimes Studies at UF and continues as a Senior Research Fellow and Director of Research for North America of CIDOEC at Jesus College, Cambridge University, England. He has addressed audiences at Cambridge University, the University of Florida, the University of London, the CIA and the U.S. State Department and created, organized and chaired over twenty conferences in Miami, Aruba, Curacao, the Bahamas, Washington, D.C., New York City, Cambridge, England and San Francisco.

Prof. Andrew P. Morriss, Esq.

Andrew P. Morriss is Dean and Anthony G. Buzbee Dean’s Endowed Chairholder at Texas A&M University School of Law. Andrew joined Texas A&M in 2014. Prior to that, he was the D. Paul Jones Jr. & Charlene A. Jones Chairholder in Law at the University of Alabama School of Law. He is the author or coauthor of more than 60 scholarly articles and book chapters. He serves as Chair of the Editorial Board of the Cayman Financial Review and was the editor of Offshore Financial Centers and Regulatory Competition (AEI Press 2010). He received his A.B. from Princeton University, his J.D. and M.Pub.Aff. from the University of Texas at Austin, and his Ph.D. (Economics) from M.I.T. He may be contacted at amorriss@tamu.edu. Contribution includes chapter 1A: A Framework for Understanding International Financial Regulation.

Martha Harris Myron, CPA

Martha Harris Myron, CPA, CFP®, JSM is an international financial planner and Principal of Pondstraddler Life™ Consultancy, Bermuda. She is a licensed certified public accountant in New Hampshire, a member of the American Institute of Certified Public Accountants, a Certified Financial Planner ™ certificant (US), and a member of the Society of Trust and Estate Practitioners (STEP – Bermuda Chapter). She is the Country Contact for Bermuda and an Appointee to the Professional Tax Advisory Council: American Citizens Abroad, Geneva, Switzerland. Martha has written extensively for more than fifteen years on domestic / international tax and finance matters in her weekly finance column “Moneywise” for The Royal Gazette, Bermuda and other international professional publications and news aggregators. Martha earned her Bachelor of Science in Accounting, and also previously owned a small U.S. tax and financial planning practice. In 2013, she received a Masters of Science of Law graduate degree in International Tax and Financial Services, Summa cum Laude from Thomas Jefferson School of Law. She may be contacted at martha.myron@gmail.com. Contributions includes Chapter 20: Ireland-U.S. Intergovernmental Agreement and Its Implementation.

Elias Neocleous, Esq.

Elias Neocleous is a partner and head of the corporate and commercial department of Andreas Neocleous & Co LLC, now one of the largest firms in south-east Europe and the Middle East. He graduated in law from Oxford University in 1991 and became a barrister of the Inner Temple. In 1993 Elias was admitted to the Cyprus Bar. He is a founder member of the Franchise Association of Greece, a member of the International Bar Association, an honorary member of the Association of Fellows of Legal Scholars of the Center for International Legal Studies, Vice President/Economy of the Limassol Chamber of Commerce and Industry, member of the Association Europeenne D’Etudes Juridiques et Fiscales, Academician of The International Academy of Estate and Trust Law, appointed by the Cyprus government to the board of directors of the Cyprus Investment Promotion Agency (“CIPA”) and Honorary Consul of Portugal. He may be contacted at eliasn@neocleous.com. His contribution includes the chapter 37: Exchange Of Tax Information And The Impact Of FATCA For Cyprus.

Danielle Nishida, Esq.

Danielle Nishida is a managing director in the International Group of KPMG’s Washington National Tax practice. Danielle joined KPMG in April 2013 and works out of the firm’s New York office, practicing in information withholding and reporting. Prior to joining KPMG, Danielle was an attorney in the Office of Chief Counsel (International) at the Internal Revenue Service from April 2009 to April 2013. At the Internal Revenue Service, she practiced in income tax withholding and Subpart F, and was a principal draftsperson of the FATCA regulations, an initial drafter of the proposed chapter 3 and 61 conforming regulations, and a drafter of other published guidance under sections 1441, 1442, 1471 through 1474, and 6050W. Danielle is a frequent speaker both in the United States and internationally regarding FATCA and other information reporting issues. Prior to joining the Internal Revenue Service, Danielle was an attorney with Burt, Staples, and Maner, LLP. She is a graduate of Georgetown University (LL.M, Taxation), Southwestern Law School (J.D.), and the University of California at Santa Barbara (B.A.). She may be contacted at daniellenishida@kpmg.com. Contribution includes chapter 14: Documenting for FATCA.

Dr. Noam Noked, Esq.

Noam Noked is a tax attorney in the Hong Kong office of Baker & McKenzie, specializing in US and international tax matters. He advises financial institutions and high net worth individuals on international wealth management matters. He also advises on US and international tax planning for cross-border businesses. He has published articles on international tax issues in academic tax journals. He graduated from Tel Aviv University and Harvard Law School (LL.M. and S.J.D. in taxation), and is admitted to the bar in Israel and New York.

 

Dr. Knut Olsen is a Chartered Global Tax Practitioner, a Chartered Transfer Pricing Specialist and a partner in Dr. K. Olsen Global Tax UK / Norway, a company that was voted as a world leading tax firm in 2015 by World Tax 2015. Mr. Olsen has 35 year of experience in taxation and specializes in international taxation, Transfer Pricing, petroleum taxation and global tax risk management. He is also a Certificated Lead ISO Auditor and has developed a system for ISO certification for Transfer Pricing, tax, VAT & customs. He may be contacted at knut.tax@gmail.com.

Rachel O’Toole, Esq.

Rachel O’Toole BA, LL.B, BL, is a barrister-at-law licensed to practice in Ireland and an attorney admitted to State Bar of California and to the Georgia State Bar. international civil litigation practices includes corporate, financial and debt related issues, planning law compliance, implementation and compliance of European environmental law, and construction and contract disputes. She is an accredited civil and commercial mediator. She has researched and presented papers on current and emerging areas of financial law, comparative legal issues, and compliance facing practitioners. Rachel has a keen interest in expanding her expertise and knowledge through challenges in practice and interdisciplinary research. She may be contacted at rachel.otoole@lawlibrary.ie. Contribution includes Chapter 20: Ireland-U.S. Intergovernmental Agreement and Its Implementation.

Haydon P. Perryman CGMA

Haydon P. Perryman CGMA is a well known industry Program Manager and Subject Matter Expert on FATCA and the CRS. He has launched and led FATCA Programs for many of the world’s largest financial institutions to support their operational compliance. He may be contacted at haydon@haydonperryman.com. His contributions include chapter 2A: FATCA Policy & Good Faith Compliance, chapter 4A: Customer Outreach, and chapter 14A: W8 Equivalents.

Darío Rajmilovich, CPA.

Darío Rajmilovich is a tax partner in Russell Bedford Argentina where he advises clients on international taxation. He graduated as a CPA at the University of Buenos Aires and he has a Taxation Specialist degree from University of Buenos Aires. He is a Graduate and Postgraduate Professor in Taxation at University of Buenos Aires, UNLP, UNS and UDESA. He is the author of books and articles in corporate income tax and international taxation. He may be contacted at drajmilovich@estudiorajmilovich.com.ar. Contribution includes chapter 38: Exchange of Tax Information and Impact of FATCA for Argentina.

Dr. Nathalie Rébé, LL.M.

Nathalie Rébé earned an LL.M. (Magna Cum Laude) in International Taxation and Financial Services at Thomas Jefferson School of Law in San Diego (California) specializing in Compliance and Risk Management and a Law degree from The University of Turin and UNICRI (Italy). She will graduate in 2015 from Thomas Jefferson School of Law with her Doctorate of Juridical Science. Miss Rébé teaches Business and Law in France. She also holds a Doctorate in Business Administration with a concentration in Financial Risk Management. She may be contacted atreben@tjsl.edu. Contribution includes chapter 45: France-U.S. Intergovernmental Agreement and Its Implementation.

Dr. Maji C. Rhee

Maji C. Rhee is a professor of Waseda University located in Tokyo, Japan where she teaches courses on language and legal communications. Rhee received her Ed.D. from Rutgers, her LL.M. in International Taxation & Financial Services from Thomas Jefferson School of Law and is currently finishing her J.S.D. dissertation on transfer pricing in Japan. She may be contacted at majirhee@gmail.com. Contribution includes chapter 21: Japan-U.S. Intergovernmental Agreement and Its Implementation.

Jean Richard, Esq.

Jean Richard, a Canadian attorney, previously worked for the Quebec Tax Department, as a Senior Tax Manager with a large international accounting firm and as a Tax & Estate consultant for a pre-eminent Canadian insurance company. He is currently the Vice President and Regional Leader Eastern Canada at BMO Financial Group. He completed a LL.L. at University of Montreal, was admitted to the Quebec Bar Association in 1981. He also completed the Canadian ‘In Depth Tax Course’ (Canadian Institute of Chartered Accountant), a Master in International Taxation with the Australian School of Taxation (ATAX), University of New South Wale, Sydney, Australia and a LL.M. in International Tax and Financial Services (International Taxation) with the Thomas Jefferson School of Law. He is a licensed financial planner. He may be contacted at jean.richard@videotron.qc.ca. Contribution includes chapter 27: Exchange of Tax Information and Impact of FATCA for Canada.

Michael J. Rinaldi, II, CPA.

Mr. Rinaldi represents U.S. and foreign institutions and families in a broad range of advisory activities including private equity real estate opportunity funds, with regard to formation, acquisitions, operations, dispositions and development of significant properties and portfolios. He is a Professor in the graduate international tax law program at Thomas Jefferson School of Law, where he teaches on Trusts, Private Equity Funds and Tax Treaties. Professor Rinaldi has authored several publications for Kluwer Law International, Jordan’s and LexisNexis. He is licensed as a certified public accountant in the District of Columbia and is a member of the International Tax Planning Association (ITPA), the Society of Trust and Estate Practitioners (STEP) and the American Bar Association, Tax Section-Partnership and US Activities of Foreigners & Tax Treaties Committees. He holds graduate degrees in accounting and tax law (both US and International). He may be contacted at MJR@RinaldiCPA.com. Contributions includes chapter 6: Determining U.S. Ownership Under FATCA; chapter 7: Foreign Financial Institutions; and chapter 8: Non-Financial Foreign Entities.

Kyra Romano-Scott, Esq.

Kyra Romano-Scott is a director of Sovereign Trust (Gibraltar) Limited, the Gibraltar office of Sovereign Group, the international corporate service provider. Kyra qualified as a Solicitor in the UK in 2000 and before moving to Gibraltar in 2006, she was in private practice in the UK specializing in matrimonial and children issues. She is a member of STEP and on the Board of the Association of Trust and Company Managers. Kyra can be contacted at kromano-scott@sovereigngroup.com and telephone +350 200 76173. Contribution includes chapter 46: Exchange of Tax Information and Impact of FATCA for Gibraltar.

William M. Sharp, Sr., Esq.

William “Bill” Sharp is the founding member of Sharp Partners PA.  Mr. Sharp has handled a multitude of international tax planning and international tax controversy cases during his thirty-year career.  In the past few years, Mr. Sharp has been active in the area of the Swiss Bank Program and FATCA. He has served as lead counsel with respect to United States Tax Court, Internal Revenue Service appeals and examination cases, and he also has served as lead counsel and co-counsel on a multitude of Internal Revenue Service voluntary disclosure cases. Mr. Sharp is a frequent speaker on international tax and business law matters, and also has been quoted in the Wall Street Journal, the New York Times, the Washington Post, Reuters, USA Today and other media on international tax topics.  Mr. Sharp has been a member of the Society of International Business Fellows since 1985, and previously served as Chairman (2001). Mr. Sharp is a member of the Board of Advisors of The Carter Center, Atlanta, Georgia. Mr. Sharp is a frequent speaker on international tax and business law matters.

Dr. Alberto Gil Soriano, Esq.

Alberto Gil Soriano is a Spanish attorney who holds a Ph.D. in Tax Law at University of Bologna (Italy), LL.M. in International Taxation and Financial Services at Thomas Jefferson School of Law in San Diego (California) and is Law degree from the University of Valencia (Spain). He has worked at the University of Valencia, at the European Commission’s Anti-Fraud Office in Brussels, and the Legal Department of the International Monetary Fund’s Financial Integrity Group, and most recently at the Inter-American Development Bank, both in Washington, D.C. He currently works at the Fiscal Department of Uría Menéndez Abogados, S.L.P in Barcelona (Spain). He may be contacted at alberto.gil@uria.com. Contributions include chapter 1: Background and Current Status of FATCA, chapter 15: Framework of Intergovernmental Agreements, chapter 18: The OECD Role in Exchange of Information: the Trace Project, FATCA, and Beyond, and chapter 28: Exchange of Tax Information and the Impact of FATCA for Spain.

Aravind Srivatsan, CA. 

Aravind Srivatsan is a Partner at PricewaterhouseCoopers Pvt. Ltd, India (PwC).  He has over 15 years of experience advising clients on managing their tax, financial and regulatory compliance matters.   He is responsible for FATCA initiative within PwC India from Tax and Regulatory perspective and is currently leading the core group of FATCA proposition including proposed implementation and reporting. He has also been involved in high level discussions with the Department of Revenue on implementation of FATCA in India and has helped clients understand the impact of FATCA on their regional and global businesses in joint initiative with PwC network offices. He may be contacted at aravind.srivatsan@in.pwc.com.  Contribution includes chapter 34: Exchange of Tax Information and Impact of FATCA for India.

Edgardo Santiago-Torres, Esq.

Edgardo Santiago-Torres is an attorney at law, principal of Santiago Law Group, LLC, and of counsel of the Knickerbocker Law Group, representing individuals and entities in corporate, taxation, and estate planning litigation. Mr. Santiago is also a Certified Public Accountant and a Chartered Global Management Accountant, pursuant to the AICPA and CIMA rules and regulations, admitted by the Puerto Rico Board of Accountancy to practice Public Accounting in Puerto Rico. He holds an LL.M. in International Taxation and Financial Services (highest honors) and a Juris Doctor (honors) of the University of Puerto Rico School of Law. He may be contacted at esantiago@santiagotorreslaw.com. Contributions include chapter 12: Withholding and FATCA and chapter 14: Determining and Documenting the Payee.

Hope M. Shoulders, Esq.

Hope M. Shoulders is a licensed attorney in the State of New Jersey. She is currently consulting for a major insurance company assisting with their implementation of FATCA. She is also an adjunct professor for the Thomas Jefferson School of Law. She previously worked for General Motors, National Transportation Safety Board and the Department of Commerce. She completed her LL.M. in International Taxation from Thomas Jefferson School of Law in San Diego, California. She authored the Indian chapter of Lexis’ Money Laundering , Asset Forfeiture & Recovery, and Compliance and is the editor of several chapters of Lexis’ Practical Guide to U.S. Transfer Pricing. She is a contributor of numerous articles and completed her thesis on OECD transfer pricing and business restructuring. She earned her J.D. and her MBA from the University of Tennessee and a Bachelors of Science from the University of Virginia. She may be contacted at shouldh@yahoo.com. Contributions include chapter 10: FATCA and the Insurance Industry and chapter 12: FATCA Withholding Compliance.

Jason Simpson, LL.M., CRA, CCA

Jason Simpson is the Director of the Miami office for Global Atlantic Partners, overseeing all operations in Florida, the Caribbean and most of Latin America. He has worked previously as a bank compliance manager and advisor at various large and mid-sized financial institutions over the past twelve years. He has been a key component in the removal of Cease and Desist Orders as well as other written regulatory agreements within a number of Domestic and International Banks, and designed complete AML/BSA units for such institutions with over ten million accounts. He is an Adjunct Faculty Member of Thomas Jefferson School of Law for Compliance, AML and Fraud, where he holds a Master of Laws in International Taxation with a concentration specialized in Anti-Money Laundering, Anti-Terrorist Financing and Compliance. Through various online venues, he creates and teaches specialized webinars in both English and Spanish focused on compliance and FATCA. He may be contacted at jsimpson@globalatlanticpartners.com. Contribution includes chapter 3: FATCA Compliance and Integration of Information Technology; and chapter 4: Financial Institution Account Remediation.

Kyriaki Stinga, Esq.

Kyriaki Stinga is a corporate and commercial attorney for Andreas Neocleous.  She holds her LL.B. from the National and Kapodistrian University (Athens) and her LL.M. (European Union Commercial Law) from Leicester.  Kyriaki may be contacted at kyriaki.stinga@neocleous.com.  Her contribution includes chapter 37: Exchange Of Tax Information And The Impact Of FATCA For Cyprus

David D.S. Stokes

David D.S. Stokes is a consultant for Andreas Neocleous & Co LLC, one of the largest firms in south-east Europe and the Middle East. He has written several publications concerning the laws and financial regulation of Cyprus. He may be contacted at david.stokes@neocleous.com. His contribution includes chapter 37: Exchange Of Tax Information And The Impact Of FATCA For Cyprus.

Daniel Sydes, Esq.

Daniel Sydes is a Director at Greenwoods & Herbert Smith Freehills Pty Limited. Daniel holds Honors Degrees of Bachelor of Commerce and of Laws, and a Masters of Banking from the University of Wollongong. Daniel specializes in income tax and advises local and international clients in the financial services, property, media and resources sectors, focusing principally on mergers and acquisitions, and the tax aspects of capital management, financing and cross-border transactions. He lectures on FATCA and the Common Reporting Standard at the University of Sydney.  He may be contacted at daniel.sydes@greenwoods.com.au. Contribution includes chapter 36: The Australia-U.S. Intergovernmental Agreement and its Implementation.

Krisztina Szombathy, Esq.

Krisztina Szombathy joined the Commercial & Litigation Department of Loyens & Loeff Luxembourg in October 2013. She specializes in dispute resolution, and advises on commercial and civil law. Her areas of expertise also include European law, energy law and intellectual property. Before joining Loyens & Loeff, Krisztina acquired experience in legal drafting, notably in European and energy law matters during an internship at the European Court of Justice in Luxembourg. Krisztina has been a member of the Luxembourg Bar since spring 2013. She may be contacted at krisztina.szombathy@loyensloeff.com. Contributions include chapter 31: Exchange of Tax Information and Impact of FATCA for Luxembourg.

Debora de Souza Correa Talutto, LL.M.

Debora de Souza Correa Talutto is the Senior Global Transfer Pricing Manager at Temenos Banking Software Co., and a professor of International Transfer Pricing and Tax Treaties at Thomas Jefferson School of Law International Tax graduate program. She has extensive experience with Brazilian tax law, having authored the Brazilian chapter of LexisNexis’ Foreign Tax and Trade Briefs, the Brazilian chapter of Lexis’ Anti Money Laundering, Asset Forfeiture, & Recovery Guide, and most recently the Cost Sharing Arrangement chapter of Lexis’ Practical Guide to U.S. Transfer Pricing. Ms. Talutto previously served as a tax consultant at Deloitte (Brazil) and Azevedo Sette Advogados (Brazil) before earning her LL.M. in International Tax from University of Florida. Currently, Ms Talutto is pursuing her S.J.D. in International Taxation from University of Florida. She holds an MBA, an LL.B. (Brazil), as well as a post-graduate degree in Brazilian taxation. Ms. Talutto may be contacted at corread@tjsl.edu or dcorrea@temenos.com. Contributions include chapter 25: Exchange of Tax Information and Impact of FATCA for Brazil.

Luis Enrique Tellez P., Esq.

Luis Enrique Tellez P. has worked at KPMG Impuestos y Servicios Legales Ltda (Colombia) for ten years, and currently works at Citibank Colombia S.A., for the past twelve years managing the Tax Department of Citi in Colombia, responsible for compliance, advisory and consulting on financial products, intra-companies transactions, implementation of transfer pricing, tax sensitive policy and FATCA, management of tax litigation, management control assessment for the tax area of Colombia, and support for expatriated taxes. He has actively participated in financial services professional associations. He has been chairman of the Legal Committee of the Banking Association Tax the past eight years and is currently a member of the Tax Committee of Experts for IFRS. He is a Colombian attorney who holds a MBA from the University of Phoenix (USA) and a law degree from Universidad Santo Tomas (Colombia). He may be contacted at letp71@hotmail.com or luis.enrique.tellez@citi.com. Contributions include chapter 40: Colombia-U.S. Intergovernmental Agreement and Its Implementation.

Dr. Mario Tenore, CA.

Mario Tenore is an associate at Maisto e Associati (Milan office). He was admitted to the Association of Chartered Accountants in 2009 and joined Maisto e Associati in 2010. He holds a Ph.D. in tax law and obtained an LL.M. Degree in international tax law from the University of Leiden, The Netherlands. His main areas of competence are corporate taxation, European and international tax law. He has extensively published in the field of International and European tax law. He may be contacted at M.Tenore@maisto.it. Contributions include chapter 48: Exchange of Tax Information and Impact of FATCA for Italy.

Andrey Tereschenko, Esq.

Andrey Tereschenko is a tax partner in the Moscow office of Pepeliaev Group LLC. He focuses on tax law and has a high level of expertise in providing advice to major Russian and foreign companies on a wide range of tax issues but especially the implementation of compensation tax arrangements. Andrey has participated in projects to set up businesses in Russia, including assessment of the tax environment in the chosen business region, investment agreements with regional authorities and tax support for due diligence. Andrey has been directly involved in tax structuring of investment projects, particularly in the sphere of construction, land and real estate acquisition. He may be contacted at a.tereschenko@pgplaw.ru. Contributions include chapter 32: Exchange of Tax Information and Impact of FATCA for Russia.

 Marie Pier Thivierge

Marie Pier Thivierge graduated from Sherbrooke University with a Bachelor of Laws (LLB).  Thereafter she obtained a Diploma of Notarial Law (DDN) and a Masters in Taxation (MFisc).  She is also a member in good standing of the Chambre des notaires du Québec.  Marie Pier has 6 years of professional experience in trusts, estates, civil law and taxation services.  Prior to joining BMO Nesbitt Burns, Marie Pier worked for major international accounting firms as a Tax Advisor in Canadian and US taxation.  She specializes in private companies, where she focused on providing clients with tax services ranging from tax compliance, estate planning, corporate structures and contracts.  She may be contacted at MariePier.Thivierge@bmonb.com. Contribution includes chapter 27: Exchange of Tax Information and Impact of FATCA for Canada.

Lily L. Tse, CPA.

Ms. Tse, a partner of Rinaldi & Associates (Washington, D.C.), represents US and foreign real estate private equity funds and property owners with regard to financial reporting and international tax matters. Her area of practice includes real estate development and leasing, joint ventures, consolidations and mezzanine financing. She has significant experience in U.S. withholding issues effecting foreign partnerships and trusts. Ms. Tse also heads the firm’s audit practice specializing in the development and operation of multi-family housing. Ms. Tse has been qualified as an expert witness in Federal Court, providing testimony in the area of real estate financing. Ms. Tse is licensed as a certified public accountant in the District of Columbia and holds graduate degrees in business and taxation. She may be contacted at LLT@RinaldiCPA.com. Contributions include chapter 7: Foreign Financial Institutions.

Sylvester Urban, Esq.

Sylvester Urban is a lawyer at King & Wood Mallesons.  He is a Barrister and Solicitor of the Supreme Court of Victoria and the High Court of Australia.  He practices in all aspects of Australian taxation (state and federal), and advises many of Australia’s largest companies across a wide range of sectors.  Mr Urban has specialist expertise in the Australian implications of the U.S. Foreign Account Tax Compliance Act and the OECD Common Reporting Standard.  Mr. Urban is a member of the Law Institute of Victoria and holds a Bachelor of Arts and an Honors Degree of Bachelor of Laws from Monash University.  He may be contacted at sylvester.urban@au.kwm.com.  Contributions include chapter 18A: The Common Reporting Standard.

Dr. Oliver Untersander, Esq.

Oliver Untersander obtained his law degree and his PhD (Law) from the University of Zurich. Her holds a LL.M. from the New York University (international tax) and is admitted to the bar in Zurich (Switzerland). He is partner at Tappolet & Partner in Zurich. He is experienced in Swiss and international corporate taxation, corporate reorganizations and tax litigation. He may be contacted at Oliver.Untersander@tappolet-partner.ch. Contribution includes chapter 23: Switzerland-U.S. Intergovernmental Agreement and Its Implementation.

Marco Valdonio, CA.

Marco Valdonio is a partner at Maisto e Associati (Milan office). He was admitted to the Association of Chartered Accountants in 2002. He joined Maisto e Associati in 2000, after working for another tax law firm and became partner in 2011. He headed the London office from 2002 to 2004. His areas of expertise comprise transfer pricing, definition of tax controversies through settlement procedures, mergers and acquisitions, financial instruments and international taxation. He may be contacted at M.Valdonio@maisto.it. Contributions include chapter 48: Exchange of Tax Information and Impact of FATCA for Italy.

Mauricio Cano del Valle, Esq.

Mauricio Cano del Valle is a Mexican attorney who has previously worked for the Mexican Ministry of Finance (Secretaría de Hacienda), Deloitte Mexico and the Amicorp Group. He is the founding partner of Brook & Cano SC, a Mexican boutique Law Firm, specializing on private clients, HNWI, UHNWI, their families and their businesses. Mauricio has been a professor at both the undergraduate and the graduate level at ITAM, the author of the book “Game Theory and Tax Evasion” published in Mexico in 2006, and the most recently published paper on “Game Theory and Minimum Taxes” included as part of a book on “Game Theory and Contemporary Law” published in Mexico in 2009. He holds a Law Degree, a Masters Degree in Law and Economics, and an MBA. He may be contacted at mcano@brookcano.com. Contribution includes chapter 22: Mexico-U.S. Intergovernmental Agreement and Its Implementation.

Michael Velten, Esq.

Michael Velten is a Financial Services Tax Partner with Deloitte in Singapore and leads the firm’s financial services tax and FATCA practices in Southeast Asia. Michael has been advising on Singapore and Asia regional tax since the early 1990s, having held senior tax roles in Asia with leading financial institutions and professional firms.    Michael is a Barrister and Solicitor of the Supreme Court of Victoria and the High Court of Australia. He is a Fellow of CPA Australia, an Accredited Tax Advisor: Income Tax and GST (Singapore), a Certified Tax Adviser (Hong Kong) and an Associate of the Chartered Tax Institute of Malaysia. Michael holds Bachelor of Commerce, Bachelor of Laws and Master of Taxation degrees from the University of Melbourne. He holds a Master of Laws degree from the National University of Singapore and a Master of Business Administration degree from the University of New England.  He may be contacted at mvelten@deloitte.com. Contributions include chapters XX: Asset Management and FATCA, XX: Singapore, XX: Philippines, XX: Cambodia, XX: Laos, XX: Myanmar, XX: Pakistan and XX: Indonesia.

Janneke Versantvoort

Janneke Versantvoort is an international tax specialist and a member of the general tax practice at Loyens & Loeff Luxembourg. She is specialized in international tax law, focusing on advising multinational clients on cross-border transactions, group restructurings, project financing and transfer pricing. She worked for three years at the Loyens & Loeff Rotterdam office and is seconded to the Luxembourg office for two years. Janneke is a member of the Dutch Association of Tax Advisers (NOB) and a member of the Young IFA in Luxembourg. She may be contacted at Janneke.Versantvoort@loyensloeff.com. Contributions include chapter 31: Exchange of Tax Information and Impact of FATCA for Luxembourg.

Axel A. Verstraeten, Esq.

Axel A. Verstraeten is an attorney partner of Levene Law Firm who graduated from the University of Buenos Aires, and holds the LL.M. in International Taxation of University of Florida. He is an Assistant Professor, University of Buenos Aires and Universidad Torcuato DiTella. He may be contacted at averstraeten@estudiolevene.com. Contribution includes chapter 38: Exchange of Tax Information and Impact of FATCA for Argentina.

John M. Walker, Esq.

John M. Walker is an international tax attorney in the U.S. who earned his LL.M. in International Taxation and Financial Services at the Thomas Jefferson School of Law. He provides international tax compliance solutions for the Foreign Account Tax Compliance Act (FATCA), passive foreign investment companies (PFICs), foreign trusts, controlled foreign corporations, and the IRS voluntary disclosure programs. He also earned a Master of Science degree in Electrical Engineering where he became a software architect. He has created systems for rapidly, accurately, and economically identifying the FATCA classification and compliance documentation for offshore trusts and entities. He has worked with FATCA clients in Australia, the British Virgin Islands, Canada, the Cayman Islands, the Cook Islands, the Netherlands, St. Kitts/Nevis, Panama, and Switzerland. He can be reached via e-mail at johnmwalker-attorney@hushmail.com, or via Skype at john.m.walker814. He is published in Tax Talk, Mertens, and Offshore Investment. Past contributions included several chapters in all three editions of the LNs Guide to FATCA Compliance, including Chapter 6: Determining U.S. ownership of Foreign Entities; Chapter 8: Non-Financial Foreign Entities; and Chapter 11: Withholding and Qualified Intermediary.

Richard L. Weisman, Esq.

Richard Weisman is a senior tax partner in the Hong Kong office of Baker & McKenzie, specializing in U.S. and international tax matters. He has occupied various leadership positions within the firm, including as Head of Baker & McKenzie’s Global Tax Practice Group and as a member of Baker & McKenzie’s Global Executive Committee. He is a frequent speaker on international tax issues, and is an active participant in internal and external programs, including those by the firm and the Tax Executives Institute. Mr. Weisman is a governor of the American Chamber of Commerce in Hong Kong, and has also served on the Executive Committee of the Hong Kong branch of the International Fiscal Association. He advises financial institutions and high net worth individuals on international wealth management matters. He also advises corporations with respect to international tax aspects of direct foreign investment, mergers and acquisitions, transfer pricing, permanent establishment concerns, tax treaty issues and dispute resolution. He graduated from Yale College and Harvard Law School, and is admitted to the bar in Massachusetts and New York.

 Dr. Mary Alice Young

Dr. Mary Alice Young is a Senior Lecturer in Law at the Bristol Law School, University of the West of England, Bristol. Dr. Young is a leading expert in the criminal misuse of offshore financial centers.  Dr. Young is also a subject expert for the Global Initiative Against Transnational Organized Crime and a contributing intelligence analyst with Open Briefing.  In October 2012, Mary gave a training workshop on offshore financial centers and money laundering for members of the Abu Dhabi police force held at the (former) SOCA headquarters. In 2013 Mary was interviewed on the subjects of money laundering and offshore banking for international publications including the LA Times, in 2014 by the Eastern Europe desk of Deutsche Welle (the German news broadcaster), the Financial Times, and was invited to speak by Dods Parliamentary Communications, and in 2015 by BBC Radio Wiltshire and the Latin Lawyer.  She may be contacted at Mary.Young@uwe.ac.uk.  Her contribution is included in chapter 1.

Prof. Bruce Zagaris, Esq.

Bruce Zagaris is a partner at the Washington, D.C. law firm Berliner, Corcoran & Rowe, LLP, where he practices tax controversy and international criminal law, including representing individuals on voluntary disclosures, audits, and litigation as well as consulting and serving as an expert witness. He represents foreign governments, including helping negotiate treaties. He is an adjunct law professor of the LL.M. in International Taxation and Financial Services at Thomas Jefferson School of Law in San Diego. Mr. Zagaris is founder and editor of the International Enforcement Law Reporter (www.ielr.com). He is the author of International White Collar Crime (Cambridge U. Press 2010) http://www.cambridge.org/aus/catalogue/catalogue.asp?isbn=9780521194686&ss=fro. He may be contacted at bzagaris@bcr-dc.com. Contribution includes chapter 16: Analysis of Current Intergovernmental Agreements.

Qiguang (Hardy) Zhou, LL.M., CPA

Qiguang (Hardy) Zhou works in the Tax group at Baker & McKenzie and is based in the Shanghai office. His practice focuses on general tax planning and tax advisory work in China. He is also a member of the Chinese Institute of Certified Public Accountants (CICPA), a member of the International Fiscal Association (IFA), a China correspondent at the International Bureau of Fiscal Documentation (IBFD), and a researcher at Center for International Tax Law of East China University of Political Science and Law. He obtained an advanced LL.M. in International Tax Law at the International Tax Center of Leiden University. He may be contacted at hardy.zhou@bakermckenzie.com. Contribution includes chapter 29: Exchange of Tax Information and Impact of FATCA for China.

Zhanna A. Ziering, Esq.

Zhanna A. Ziering is a Senior Associate in Caplin & Drysdale’s New York Office.  Over the years, Zhanna has represented hundreds of taxpayers worldwide in connection with the IRS’s and DOJ’s investigation of unreported foreign assets and accounts in federal and state voluntary disclosure programs and in audits.  She also advises individual and corporate clients on various tax issues, including civil fraud audits, U.S. and state residency audits, and the U.S. reporting requirements relating to offshore assets.  Zhanna frequently speaks on the IRS’s and DOJ’s enforcement initiatives relating to the investigation of unreported offshore assets.  Prior to joining Caplin & Drysdale in 2011, Zhanna was a tax controversy associate with an international law firm in New York where her practice was focused on defending corporations and individuals in federal and state investigations and litigation involving tax shelter promoters and investors.  She may be contacted at zziering@capdale.com.  Her contribution is Chapter 1B U.S. Offshore Account Enforcement Issues.

4 Responses to “FATCA”

  1. […] FATCA […]

    Like

  2. […] FATCA […]

    Like

  3. […] FATCA […]

    Like

  4. Paras Savla said

    CA Paras Savla, is a fellow member of the ICAI, Certified Fraud Examiner (CFE) USA, DISA (ICAI). Prior to that he has had a stint with one of the Big 4 Accounting Firm. He has advised several corporate on issues relating to domestic tax, international taxation, routing investment into India, structuring the transactions, outbound investments, drafting contracts, conducting due diligence and planning for mergers/ demergers, acquisitions, direct tax litigations and corporate finance. He is regularly writes for various newsletters, magazines, newspapers on the topics of Direct Taxes & Corporate Laws.
    He has addressed audiences at various seminars, forums and conferences and has also presented background papers on various topics of professional interest. He is also the regular speaker at various forums. He has been regularly involved for representing on laws and regulation before various Government Authorities. He had also held various leadership positions with the professional organization. He was President of The Chamber of Tax Consultants (Est. 1926) and CVO Chartered & Cost Accountants’ Association (Est. 1974) during the year 2014-15 and 2013-14 respectively. He was managing committee member of Indian Merchant Chambers (Est. 1907) for the year 2013-14. He is also the member of various professional and trade organizations. He is actively engaged in mentoring articled students and young professionals.

    Like

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s

 
%d bloggers like this: