April 2011 – Tax, Estate Planning & Probate Law Center

Time Running Out for HSBC India accountholders sought by IRS

28 Apr 11

If HSBC produces these records, which is likely, it may be too late for U.S. taxpayers with undisclosed HSBC accounts to take advantage of the IRS Voluntary Disclosure Program for offshore accounts.

HSBC Expected to Disclose Account Holders Names

19 Apr 11

The IRS has petitioned for a federal court authorization to enable it to obtain information on HSBC Bank’s American account holders using their foreign accounts to evade taxes. Most of these account holders are believed to be Americans of Indian

IRS examines jewelry, precious stones and metals businesses for compliance

17 Apr 11

The IRS is conducting Anti-Money Laundering examinations (similar to tax audits) of jewelry, precious stones (including colored gems, diamonds, etc.), and precious metals businesses. The IRS is now in charge of compliance with the Anti-Money Laundering Rules. The Anti-Money Laundering

HSBC Client Pleads Guilty to Conspiring to Hide Indian Accounts From IRS

17 Apr 11

An Indian-American businessman on Tuesday pleaded guilty to conspiring to defraud US tax authorities by hiding his bank accounts in HSBC India, a case which has led the IRS to probe NRIs holding accounts in the bank. Vaibhav Dahake, 44

IRS list of “dirty dozen” tax scams

15 Apr 11

Hiding income in offshore accounts, identity theft, return preparer fraud, and filing false or misleading tax forms top the annual list of “dirty dozen” tax scams in 2011, the Internal Revenue Service announced today. “The Dirty Dozen represents the worst

Foreign bank account reports (FBARs) and the 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI)

11 Apr 11

Foreign bank account reports (FBARs) for 2010 are due on June 30, 2011 (and no extension is available). Recent guidance provides insight into who is required to file an FBAR and what is considered to be a “foreign financial account”

IRS’ Takes Legal Action Against Offshore HSBC Indian Accounts

10 Apr 11

Last week the U.S. Justice Department asked a federal district court in San Francisco to force HSBC USA to disclose the names of their U.S. customers suspected of having secret bank accounts in India. The legal action comes after the

Post IRS Audit Strategic Options: The IRS’ 30 Day Letter

09 Apr 11

If, after conducting the audit, a taxpayer and revenue agent cannot come to an agreement, the agent will prepare and submit to the taxpayer a preliminary notice of deficiency, or “30-day letter.” The 30-day letter is a form letter that sets

New Jersey Division of Taxation Now Issuing Letter Rulings

03 Apr 11

The New Jersey Division of Taxation recently announced that it will implement new procedures for taxpayers to obtain letter rulings. Similar to letter rulings issued by the Internal Revenue Service with regard to federal tax issues, letter rulings issued by

New Law’s Reporting Requirements Make It Very Likely That the IRS Will Now Know About Your Foreign Account

02 Apr 11

you should assume that the IRS will eventually be informed of your foreign account, and criminal prosecution for non-disclosure and non-reporting will likely follow