Another HSBC Customer Likely Going to Jail
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
Off the Cliff Commentary About the New 2013 Tax Law
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
New Comments of the IRS’ New Streamlined Filing Compliance Procedures for Non-Resident Non-Filer U.S. Taxpayers
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
Benefits and consequences of entering or failing to enter the Offshore Voluntary Disclosure Initiative program
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
Tax Planning Opportunities for High Net Worth Individuals
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
Tax Planning Opportunities for Business Owners
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 ■
New Tax Planning Opportunities for High Income Individuals
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
Upcoming 2013 Tax Provisions Which Will Impact Planning Opportunities
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
2012 Offshore Account Criminal Tax Cases
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
IRS Notices for OVDI Program
When the IRS receives payment with amended tax returns for taxes, interest and penalties, the IRS may misapply the payment. This results in IRS notices. Reminiscent of the mistakes of the 2009 OVDP, the IRS
Top 10 factors to consider before deciding to opt out of OVDI or OVDP
While opting out of the OVDI or OVDP amnesty programs may result in a reduction of penalties that may otherwise be assessed, the taxpayer needs to carefully weigh the numerous consequences before doing so. Responsible
Foreign Account Tax Compliance Act (FATCA): More Information Sharing Agreements Expected
FATCA was enacted in 2010 by Congress to target non-compliance by U.S. taxpayers using foreign accounts. FATCA requires foreign financial institutions (FFIs) to report to the IRS information about financial accounts held by U.S. taxpayers,