Regulatory Analysis

Posted June 10, 2017 by Tom Hospod
Senate Leadership Invokes Rule to Fast-Track Healthcare Legislation

Senate negotiations regarding the fate of the American Health Care Act are continuing in spite of the discord among and between Democrats and Republicans on a number of provisions in the bill. Much of the roadblocks at this point are procedural in nature regarding the Reconciliation rules. A failure to comply with Reconciliation requirements would […]

Read more
Posted June 10, 2017 by Tom Hospod
American Health Care Act Would Maintain Employer Reporting Requirements

Proposed ACA replacement legislation, entitled the American Health Care Act (AHCA), aims to dismantle the employer mandate by zeroing out the associated penalties. Despite this, the AHCA maintains both employer and insurer reporting requirements. There are seven high-level changes to the current law that the AHCA will seek to impose: Nullify Individual Mandate […]

Read more
Posted June 10, 2017 by Tom Hospod
Rep. MacArthur Proposes Amendment to AHCA Allowing State Waivers

Congressman Tom MacArthur has authored an amendment to the American Health Care Act (AHCA) that would provide greater flexibility to states by allowing them to request waivers from any of three key AHCA provisions: The 5:1 Age Rating Ratio: The age rating ratio, which is already being increased from 3:1 to 5:1, will be […]

Read more
Posted June 10, 2017 by Tom Hospod
AHCA would both Expand and Simplify Current Reporting Requirements

If the American Health Care Act (AHCA) becomes law, the IRS would expect employers to report as they did under the ACA. The IRS would also continue to enforce penalties for late, missing, inaccurate and incomplete information returns.   Even with the bill’s nullification of Employer Mandate penalties, reporting would remain mandatory in its current […]

Read more
Posted June 10, 2017 by Tom Hospod
House Passes American Health Care Act with Amendments

The amended American Health Care Act (AHCA) passed by the House expanded upon the prior version, but made certain adjustments providing individual states more flexibility in shaping and regulating their own insurance markets. The new bill also appropriates $8 billion over five years to subsidize coverage for pre-existing conditions in an attempt to offset the fiscal impacts of permitting […]

Read more
Posted June 10, 2017 by Tom Hospod
ACA Compliance Validation System Delayed Until May 2017

The Treasury Inspector General for Tax Administration (TIGTA) recently announced the delay of the ACA Compliance Validation (ACV) System, which is now expected to be implemented in May 2017. Employers should be aware that this delay does not impact their reporting obligations and potential liabilities for penalties. The ACV system’s purpose is to determine compliance […]

Read more
Posted June 9, 2017 by Tom Hospod
Cyprus Opens Data Transmission Portal and Releases FATCA Specifications

The Cypriot Ministry of Finance has announced that its Government Internet Security Channel is now open for the acceptance of FATCA and CRS XML files containing tax year 2016 data. The reporting process consists of the following steps: Subscribe to the Internet Security Channel if you are not already registered Register to the […]

Read more
Posted June 9, 2017 by Tom Hospod
Curacao FATCA Testing Period Opens Late, Deadline to Be Delayed

The Curacao Financial Data Exchange Portal is now open for the FATCA XML file testing period. The testing period, which was originally scheduled to begin on May 29, was delayed due to technical difficulties. As such, the data delivery functionality and reporting deadlines will also be delayed to dates which will be determined at a […]

Read more
Posted June 9, 2017 by Tom Hospod
Guatemala Ratifies the Convention on Mutual Administrative Assistance in Tax Matters

The Guatemalan government has adopted the Convention on Mutual Administrative Assistance in Tax Matters in a move to demonstrate its commitment to tax transparency and remove itself from a “blacklist” of international tax havens. Once it takes the necessary legislative steps to implement the OECD programs, Guatemala will be able to exchange information with […]

Read more
Posted June 8, 2017 by Paul Ogawa
Rhode Island Removes Annual Reporting Frequency for Employer Withholding Tax

Rhode Island recently updated their reporting frequency schedule to exclude the annual reporting frequency. The update to the 2017 Employer’s Income Tax Withholding Tables and the removal of Form RI-941A from the Department of Revenue website confirm that filers previously on an annual reporting schedule must switch to one of the remaining reporting schedules – […]

Read more
Posted June 7, 2017 by Sovos
Ireland Extends CRS Filing Deadline to August 18th

  Irish Revenue has sent correspondence to all interested parties indicating that the deadline for filing CRS returns has been extended from June 30th to August 18, 2017 due to the late delivery of the required business and validation rules – resulting in a delay to the start of filing. Although the submission application is […]

Read more
Posted June 6, 2017 by Lee Pender
IRS Issues Revised Publication 5118, FATCA Online Registration User Guide

The IRS has published an updated version of its FATCA Online Registration User Guide. The purpose of this publication is to guide Financial Institutions and Direct Reporting Non-Financial Foreign Entities (NFFEs) to register themselves and their branches as a Participating Foreign Financial Institution (PFFI), a Registered Deemed-Complaint FFI (RDCFFI), a Sponsoring Entity, a Direct Reporting […]

Read more
Posted June 6, 2017 by Lee Pender
Germany Publishes New CRS Infobrief

The German Tax Office has published a new Infobrief containing information relevant to this year’s CRS filing season. The Infobrief covers a variety of topics, including the following: Opening of CRS production environment: Filers are now able to transmit CRS data as of June 1, 2017. The portal will be open for transmittals through […]

Read more
Posted June 6, 2017 by Lee Pender
Croatia Revises Web Application User Manual for FATCA

The Croatian Tax Administration has issued a revision of its Web Application User Manual to be used in conjunction with FATCA transmittals. The Manual has two substantive updates that should be noted: The Manual now includes a link to access the web application’s production environment for transmitting FATCA XML files to the competent authority. […]

Read more
Posted June 6, 2017 by Lee Pender
Hong Kong Publishes Instructions for Occupational Retirement Schemes (ORS)

In response to the submissions made through the OECD disclosure facility, Hong Kong’s Inland Revenue Department has published guidance for the use of Occupational Retirement Schemes.  In part, the guidance instructs that only those schemes registered under the proper ordinance are considered non-reporting financial institutions. The post Hong Kong Publishes Instructions for Occupational Retirement Schemes […]

Read more
Posted June 6, 2017 by Lee Pender
Portugal Releases FATCA Schema Guidance

Portugal has released guidance for the proper formatting of FATCA XML returns.  Portuguese Financial Institutions should review the document before the July 31 due date to ensure that their return will be compliant. The post Portugal Releases FATCA Schema Guidance appeared first on Sovos.

Read more
Posted June 6, 2017 by Lee Pender
Bulgaria Will use OECD’s CRS Schema

Bulgaria has recently announced that it will require its Reporting Financial Institutions to use the schema designed by the OECD for this month’s CRS reporting.  On its AEOI website, Bulgaria has provided samples and schema files to assist.  In addition, there is a list of Reportable Jurisdictions published.  As a reminder, CRS reports are due […]

Read more
Posted June 6, 2017 by Lee Pender
OECD Gets First Results from Disclosure Facility

Last month, the OECD launched its public disclosure facility in order for interested parties to submit potential schemes they believe are being used to circumvent the Common Reporting Standard.  The facility’s goal is to understand these schemes or loopholes to further strengthen CRS’s effectiveness in promoting greater transparency.  Within a month, the OECD had received […]

Read more