Daily Tax Update - July 13, 2015: US and Philippines Sign Model 1 IGA

US and Philippines Sign Model 1 IGA:  Today the Philippines and the US signed an intergovernmental agreement (IGA) to implement the Foreign Account Tax Compliance Act.  The new agreement amplifies the existing tax treaty between the two countries by introducing annual automatic reporting of financial accounts maintained by US persons in Philippine financial institutions.


Tax Court Holds Purported Welfare Benefit Plan to be Split-Dollar Life Insurance Arrangement:  Today, in Our Country Home Enterprises, Inc. v. Commissioner, the US Tax Court held that a closely-held corporate employer was not entitled to deduct payments on a split-dollar life insurance plan, which paid death, medical, and disability benefits to participating employees.  The court further held that the employees were required to recognize income from the plan.  The opinion notes that 40 other cases pending before the court have agreed to be bound by one or more of the final decisions in this case.