TaxProf Blog

Editor: Paul L. Caron, Dean
Pepperdine University School of Law

Tuesday, March 31, 2009

House Holds Hearing Today on Banking Secrecy Practices and Wealthy American Taxpayers

The Subcommittee on Select Revenue Measures of the House Ways & Means Committee holds a hearing today on Banking Secrecy Practices and Wealthy American Taxpayers. From the hearing advisory:

The hearing will focus on limitations of the withholding taxes imposed by the United States on U.S. source investment earnings received by foreign persons, the Qualified Intermediary (QI) program established by the IRS to enforce those withholding taxes, the limitations of our tax treaties, and the extent to which these may have contributed to non-compliance by U.S. taxpayers. It will use the current UBS case as an example of the problems in the existing system.

Here are the witnesses statements:

In connection with the hearing, the Joint Committee on Taxation has released Tax Compliance and Enforcement Issues With Respect to Offshore Accounts and Entities (JCX-23-09):

This document ... provides background on withholding and information reporting requirements applicable to payments of U.S.-source portfolio investment income to nonresidents, the IRS Qualified Intermediary program, the effect of bank secrecy laws and practices on U.S tax compliance and enforcement efforts involving offshore accounts, and information exchange procedures under U.S. income tax treaties and tax information exchange agreements.

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