Old Tricks for New Dogs, Part II: The OECD’s Cryptoasset Reporting Framework

By Paul Foster Millen & Peter A. Cotorceanu, 8 Apr, 2024

Meet the “new dogs”! There are packs of them. As we mentioned in our previous article in this series, 1 “old tricks” refers to the fact that the OECD’s cryptoasset reporting framework (CARF2) is based heavily on the OECD’s common reporting standard (CRS3), which was published almost a decade ago.

Old Tricks for New Dogs: The OECD’s Cryptoasset Reporting Framework

By Paul Foster Millen & Peter A. Cotorceanu, 16 Oct, 2023

Why “old tricks”? Because the OECD’s cryptoasset reporting framework (CARF) is based heavily on another automatic exchange of information regime that was published almost a decade ago: the OECD’s common reporting standard (CRS).

Forming financial intermediaries into a fifth column: the OECD MDRs for CRS avoidance

By Paul Foster Millen & Peter A. Cotorceanu, 01 Apr, 2019

The professional plight of fiduciaries, lawyers, accountants, and other advisors who aid their clients in minimizing their tax burden rarely turns a dry eye wet.

The Inside Story of the Crooks and Kleptocrats Who Rule the World

By Oliver Bullough, 2018

Peter Cotorceanu is quoted a few times in the chapter titled Tax Haven USA.

A Fiduciary’s Survival Guide: Paul Foster Millen and Peter Cotorceanu
offer advice on the upcoming FATCA
responsible officer certifications

STEP Journal, By Paul Foster Millen & Peter A. Cotorceanu, Nov, 2018

In absolute terms, US financial institutions (FIs) have been let off rather lightly by the Foreign Account Tax Compliance Act (FATCA).

The Small Print: Paul Foster Millen and Peter Cotorceanu detail when and why FATCA responsible officers ofModel-1 IGA sponsors have IRS certification obligations

STEP Journal, By Paul Foster Millen & Peter A. Cotorceanu, Mar, 2018

Trustees and other fiduciaries sponsoring structures must act promptly to affirm that their sponsored trusts and other sponsored entities have been compliant with the full set of obligations under the US FATCA Regulations, and that they can meet the RO certification requirements.

Paul Foster Millen and Peter Cotorceanu
ask: are US corporate trustees about to be ambushed by FATCA?

STEP Journal, By Paul Foster Millen & Peter A. Cotorceanu, Jan, 2018

In absolute terms, US financial institutions (FIs) have been let off rather lightly by the Foreign Account Tax Compliance Act (FATCA).

More Honesty and Less Hypocrisy on Shell Companies

New York Times, By Peter A. Cotorceanu, Apr 7, 2016

The U.S. should absolutely not do more to crack down on overseas shell companies, but should certainly do more to crack down on its own domestic shell companies.

Why America Loves Being the
World’s No. 1 Tax Haven

Politico.com April 8, 2016 By Peter A. Cotorceanu

Much ink has been spilled in recent days about the Panama Papers and the perfidy of foreign leaders from Vladimir Putin to the (now-resigned) prime minister of Iceland...

Hiding in plain sight: how non-US persons can legally avoid reporting under both
FATCA and GATCA

Trusts and Trustees, October 2015, Peter A. Cotorceanu

How non-US persons can legally avoid reporting under both FATCA and GATCA?

FATCA and Offshore Trusts:
The First Nibble

Tax Analysts 2013 - By Peter A. Cotorceanu

How do you eat an elephant? One bite at a time. The same is true of the Foreign Account Tax Compliance Act, except that FATCA’s no elephant. It’s a leviathan. And it breathes fire...

FATCA and Offshore Trusts:
A Second Bite of the Elephant

Tax Analysts 2013 - By Peter A. Cotorceanu

Trusts. Foreign financial institutions. Square pegs. Round holes. Think back, if you can, to a world before the Foreign Account Tax Compliance Act....

FATCA and Underlying Companies:
Pin the Tail on the Elephant

Tax Analysts 2014 - By Peter A. Cotorceanu

The Foreign Account Tax Compliance Act treatment of offshore trusts is a mess. That’s the good news. FATCA’s treatment of the underlying companies (UCs)...