The IRS recently posted guidance in its OVDI FAQs (#51) whether taxpayers should opt out of the 2011 Voluntary Disclosure Initiative’s (the “OVDI”) civil penalty structure. Taxpayers who participate in the OVDI, but feel that their
Our firm recently informally met with a US Department of Justice official (name withheld because official was not authorized to officially speak) in Washington DC regarding the pending summons served on HSBC India to reveal
Our office is advising dozens of clients (including many HSBC customers) regarding offshore accounts, all of whom may be subject to large unfair penalties. Finally it appears that someone in government is realizing the unfairness
Tomorrow night our firm will be presenting a three hour seminar to tax professionals on foreign account disclosure, FBARs, and OVDI at the Academy of Continuing Professional Education (ACPE): June 21, 2011 – 7:00 p.m.
The IRS last week explained fully the possibility of opting-out of the OVDI and taxpayers’ taking their chances with an IRS examination, particularly where the non-disclosure of assets or income could be proved to not
The IRS said last week that it is making available to taxpayers a 90-day deadline extension to participate in the 2011 offshore voluntary disclosure initiative (OVDI). The extension would be available to taxpayers who have
The Department of Justice and local United States Attorneys’ Offices continue to zealously prosecute numerous cases involving U.S. taxpayers who have failed to report their interests in offshore accounts. The successful prosecutions underscore the government’s
Last week a Boston venture capitalist and director at a Boston bank was charged with failing to report his foreign bank account and income to the US Department of the Treasury. It is noteworthy that
The US Internal Revenue Service (IRS) has asked HSBC Bank to provide information on incomes of US residents who may be using accounts in India to evade income taxes. The move has raised several questions.
In an effort to reach all taxpayers, including those ensnared in the pending HSBC subpoena to disclose customer names of non-resident indian customers with offshore accounts, the IRS has published its OVDI materials in Hindi.
On April 13, 2011, another U.S. taxpayer with an offshore HSBC bank account, Josephine Bhasin (United States v. Bhasin, E.D.N.Y., No. 11-cr-00268-ADS), pled guilty to charges of knowingly filing false tax returns, false amended tax
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.
