Wealth & Risk Management Blog

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

Posts Tagged ‘narcotics’

A Proposal to Leverage FATCA to Punish Black and Grey Hat Governments.

Posted by William Byrnes on February 16, 2017


please download my proposal https://ssrn.com/abstract=2916444

Abstract: Professor William Byrnes examines whether it is prudent for taxpayers to trust the governments of the 117 countries that scored a fifty or below on Transparency International’s Irs_logocorruption index. The complete information system invoked by the Foreign Account Tax Compliance Act (FATCA) encourages, even prolongs, the bad behavior of black hat governments by providing fuel (financial information) to feed the fire of corruption and suppression of rivals. Professor Byrnes recommends that the United States leverage a “carrot-stick” policy tool to incentivize bad actors to adopt best tax administration practices.  Article download at https://ssrn.com/abstract=2916444

Keywords: FATCA, Common Reporting Standards, OECD, Exchange of Information, Taxpayer Rights, IGA, corruption

Professor William Byrnes is the primary author of Lexis’ Guide to FATCA and Common Reporting Standard Compliance – 2017.  He designed then wrote the initial 2012 edition and has grown it to the #1 FATCA resource for advisors and institutions.  Now in its fifth edition for 2017!

Over 1,800 pages of analysis of the FATCA and CRS compliance challenges,  79 chapters by FATCA and CRS contributing experts from over 50 countries. Besides in-depth, practical analysis, the 2017 edition includes examples, charts, timelines, links to source documents, and compliance analysis pursuant to the IGA, CRS agreement, and local regulations for many financial centers.   This fifth edition will provide the financial enterprise’s FATCA and CRS 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 forthcoming 2017 edition – http://www.lexisnexis.com/store/catalog/booktemplate/productdetail.jsp?pageName=relatedProducts&prodId=prod19190327

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Court Grants US Extraterritorial Search of Emails

Posted by William Byrnes on September 17, 2014


Feds Pose Privacy Risk by Grabbing Overseas ISP E-mails

read the synopsis by the law firm of Pepper Hamilton LLP …

Warrant Issued Pursuant to the SCA

This matter began with an application by the United States for a “search and seizure warrant” targeting a specific @msn.com e-mail account provided by Microsoft, and used by a person who is the subject of a government narcotics investigation. Magistrate Judge James C. Francis IV issued the warrant, after which Microsoft undertook to locate the data associated with the account. Microsoft determined that there were two buckets of data related to the account, one stored in the United States and the other in Ireland.

The “noncontent” bucket consisted of information such as the sender and recipient e-mail addresses as well as date and time information. Microsoft stored this information in the United States, and produced it in response to the warrant. The “content” bucket of information included the substance of the e-mails and their subject lines. For this particular user, Microsoft stored this information at a data center operated by a Microsoft subsidiary in Dublin, Ireland. Microsoft did not produce this information and instead moved to quash the warrant to the extent that it required information from the Dublin data center. Notably, Microsoft began the practice of using foreign data centers in 2010 to address the problem of “latency” that occurred when the servers were too far away from the user. The Irish data center would typically serve users that live closer to Ireland than the United States.

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