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IRS International Operations U.S. Embassy Beijing Chinchie Killfoil, Tax Attaché

IRS International Operations U.S. Embassy Beijing Chinchie Killfoil, Tax Attaché. A Few Details About IRS. Bureau of Department of Treasury Collects more than $ 2.7 trillion USD in revenue yearly to fund the U.S. Government Processes 250+ million tax returns

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IRS International Operations U.S. Embassy Beijing Chinchie Killfoil, Tax Attaché

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  1. IRS International OperationsU.S. Embassy BeijingChinchie Killfoil, Tax Attaché

  2. A Few Details About IRS • Bureau of Department of Treasury • Collects more than $ 2.7 trillion USD in revenue yearly to fund the U.S. Government • Processes 250+ million tax returns • Spends 41 cents for every $100 collected • 98,000 employees

  3. Goal 2: Enforce the law to ensure everyone meets their obligation to pay taxes Goal 1: Improve service to make voluntary compliance easier IRS Strategic Goals Strategic Foundation: Invest for High Performance T 2-4

  4. Services and Enforcement 88,000 employees

  5. IRS Commissioner LB&I International Function Commissioner Large Business & International EOI Program IRS Deputy Commissioner for Services & Enforcement Treaty Unit JITSIC Deputy Commissioner (International) Assistant Deputy Commissioner (Int’l) Foreign Posts Service-wide Strategy Director, International Business Compliance (IBC) Director, Transfer Pricing Operations Director, International Individual Compliance (IIC) International Exam Function International Exam Function APMA Program Transfer Pricing Practice

  6. Large Business and InternationalLB&I • Serves 210,000 taxpayers • Businesses with $10 million + assets • Large multinational companies • Complex issues • Serves International taxpayers (IBC & IIC) • 7,800 employees (1,700 devoted to international, the rest domestic large case) • 4 overseas posts (CI has 10 overseas posts)

  7. Kelli Winegardner Tax Attaché London Barbara Franklin Tax Attaché Frankfurt Chinchie Killfoil Tax Attaché Beijing Aziz Benbrahim Tax Attaché Paris JD Carroll Director JITSIC Washington DC Frankfurt London Plantation, FL Washington DC Paris Beijing Exchange of Info around the World Dean Burke EOI Program Mgr Washington DC Raul Pertierra Rev Service Rep Plantation, FL SEP 07 2011

  8. Regional Responsibilities… • Beijing: Asia • London: UK, Scandinavia, Africa • Paris: Mid-East, Western & Southern Europe • Frankfurt: Central & Eastern Europe, Central Asia, Mid-East • Plantation, Florida: Caribbean Islands, Central and South America

  9. So, what is a Tax Attaché? • Competent Authority’s representative for their regional area • Manage Exchange of Information (EOI) with foreign governments • Establish and maintain relationships with Treaty Partners • Provide Service to U.S. Taxpayers abroad • Eyes and ears of IRS in foreign jurisdictions

  10. Exchange of Information It is done under - • Bilateral Treaties • Tax Information Exchange Agreements (TIEA) • OECD/Council of Europe Convention on Mutual Administrative Assistance in Tax Matters (Multilateral Treaty) • Mutual Legal Assistance Treaties (MLAT) • Hague Evidence Convention

  11. Common information exchanged: • Bank, brokerage & other financial records • Witness interviews • Business records • Public records • Real estate ownership records • Accountant & attorney records • Insurance company records

  12. Common information exchanged… • Tax return information • Record of filing • Filing status • Amount of taxes paid • Types, sources, and amounts of income • Address of residency (residency) ANY information related to tax investigation!

  13. Types of EOI Requests • Specific – for specific taxpayers • Spontaneous –provided without request - information might indicate non-compliance • Automatic – information exchanged on a routine, systemic basis • Simultaneous – both US & treaty partner examine same TP or related TP with common issues • Industry-wide – industry or sector about trends, practices, pricing, etc.

  14. Recent Developments - FATCA • Two components • Foreign Financial Institutions (FFI) Identify United States Accounts and report directly to the IRS on Form 1099-FFI • U.S. taxpayers report foreign financial asset holdings on Form 8938 starting with 2011 tax return if certain thresholds are met.

  15. Recent Developments - FATCA • Foreign Financial Institutions (FFI) Identify United States Accounts and report directly to the IRS on Form 1099-FFI • FFI to register on-line starting 1-1-2013 • FFI to report Name, Address, TIN & Account Balance (reporting starts in 2014 with respect to 2013) • Income Amounts (reporting starts in 2016) • Gross Proceeds (reporting starts in 2017)

  16. Recent Developments - FATCA • For more information please visit the FATCA Page on www.irs.gov • More FATCA information in another session later. Questions?

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