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Category: Planning for Tax Minimization

HSBC Payment of Largest Penalty and FATCA Encourages Taxpayers to Disclose

30 January, 2013

Last month, HSBC Holdings agreed to pay $1.92 billion in fines to U.S. authorities, which is the largest collective settlement in the Treasury Department’s history. The penalty assessment was based upon HSBC’s conduct in violation

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Important Provisions of the American Taxpayer Relief Act of 2012

25 January, 2013

On January 1, 2013, Congress passed the American Taxpayer Relief Act of 2012 (“Act”) which was signed into law on January 2, 2013. While certain provisions of the Act are considered to be “permanent”, an

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Bank Leumi: Another Foreign Bank Recommends the IRS Voluntary Disclosure Program

23 January, 2013

Bank Leumi is urging its U.S. clients to disclose information about their accounts to U.S. authorities investigating Leumi and many other foreign banks over possible tax avoidance by Americans. In a December 16 letter Leumi

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Another HSBC Customer Likely Going to Jail

11 January, 2013

Last week a New Jersey client of HSBC Holdings Plc (HSBA) pleaded guilty to charges that he hid as much as $4.7 million through Swiss and Indian accounts not declared to the U.S. Internal Revenue

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Off the Cliff Commentary About the New 2013 Tax Law

2 January, 2013

As predicted, Congress waited until the last minute to make a deal, technically after we plunged off the fiscal cliff to pass a new tax law. The new 2013 tax law, in summary, is below

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New Comments of the IRS’ New Streamlined Filing Compliance Procedures for Non-Resident Non-Filer U.S. Taxpayers

22 December, 2012

I just returned from the American Bar Association Section of Taxation’s annual National Institute on Criminal Tax Fraud in Las Vegas. A topic of discussion was the relatively new New Streamlined Filing Compliance Procedures for

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Benefits and consequences of entering or failing to enter the Offshore Voluntary Disclosure Initiative program

29 November, 2012

Over the past several years our law firm has counseled hundreds of non-compliant U.S. taxpayers in the exploration of their legal options with respect to the Offshore Voluntary Disclosure Initiative programs.  As a result, we

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Tax Planning Opportunities for High Net Worth Individuals

7 November, 2012

Despite the election results, taxes are going up!  Although major tax law changes are set to take place in 2013, there are opportunities for high net worth individuals. Below are a few planning opportunities. Tax Provisions

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Tax Planning Opportunities for Business Owners

3 November, 2012

Unless Congress acts quickly, taxes are going up!  Although major tax law changes are set to take place in 2013, there are some planning opportunities for business owners: Tax Provisions Which May Impact Planning Opportunities ■      

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New Tax Planning Opportunities for High Income Individuals

30 October, 2012

To help appreciate the planning opportunities individuals may have between now and year end, we have prepared a summary of the key tax law provisions affecting high income individuals. Tax Provisions Which May Impact Planning

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Upcoming 2013 Tax Provisions Which Will Impact Planning Opportunities

26 October, 2012

Unless Congress acts quickly, taxes are going up!  Although major tax law changes are set to take place in 2013, uncertainty makes it hard for families and businesses alike to plan ahead. Below are the expected

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2012 Offshore Account Criminal Tax Cases

19 October, 2012

The Department of Justice continues to prosecute cases involving United States taxpayers who have failed to report their interests in offshore accounts. Most of the cases are for large offshore accounts, but they provide good guidance

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