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Month: December 2013

More Swiss Banks Agree to Cooperate with the IRS

31 December, 2013

Lombard Odier & Cie and VP Bank (Switzerland) last week became the latest Swiss banks to say they would work with U.S. officials in a crackdown on lenders suspected of helping wealthy Americans evade taxes

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U.S. Signs FATCA Pacts with Malta, Netherlands, Bermuda, Jersey, Guernsey and Isle of Man

28 December, 2013

Last week, the U.S. signed six more intergovernmental agreements with a half dozen jurisdictions, including several traditional offshore tax havens, to implement the Foreign Account Tax Compliance Act, or FATCA. Over the past week, the

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Argue for No Penalty and a Warning Letter for FBAR Violations

22 December, 2013

The IRS may send a warning letter in lieu of asserting penalties for failure to file a Form TD F 90-22.1, “Report of Foreign Bank and Financial Accounts,” if it would be sufficient to bring

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Swiss Banks are Pressuring Customers to Disclose

21 December, 2013

Swiss banks are pressuring current and former U.S. account holders to disclose undeclared assets to the Internal Revenue Service. In some cases, the banks are freezing accounts unless clients can prove they have declared the

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US Department of Justice Encourages Swiss banks to Disclose Information

15 December, 2013

Last week the Tax Division of the Department of Justice strongly encouraged Swiss banks that want to seek non-prosecution agreements to resolve past cross-border criminal tax violations to submit letters of intent by the Dec.

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Method to Cure Delinquent or Incomplete Foreign Information Returns Without Penalties

14 December, 2013

Last year, the IRS announced its third offshore voluntary disclosure initiative. Like the earlier initiatives, the 2012 OVDP is designed to encourage taxpayers with unreported offshore accounts and assets to voluntarily disclose them to the

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More Swiss Banks Agree to Disclose US Customers Accounts: Expect More Customer Letters to be Sent

12 December, 2013

As of yesterday, three Swiss banks have agreed to participate in a U.S. disclosure program aimed at lenders suspected of aiding tax evasion by Americans.  Many more expected and thousands of letters are being sent

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Comparison of Form 8938 and FBAR Requirements

9 December, 2013

The new Form 8938 filing requirement does not replace or otherwise affect a taxpayer’s obligation to file FinCEN  Form 114 (Report of Foreign Bank and Financial Accounts). Individuals must file each form for which they

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