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
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
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
The Bank Secrecy Act (“BSA”) was originally enacted in 1970 to help detect and prevent money laundering. The BSA requires reporting for a calendar year called a “Report of Foreign Bank and Financial Accounts” (Form
The Praxair (Praxair Technology, Inc. v. Director, Div. of Taxation, N.J. App. Div., Docket No. 4-6262-06T3 (Sept. 1, 2010) case involved a taxpayer that received its assessment prior to the start of amnesty. If you
The New Jersey Department of Treasury, Division of Taxation announced today that it will offer a Second Voluntary Compliance program to complement the Internal Revenue Service Second Special Voluntary Disclosure Initiative to identify assets and
We have reviewed the new 2011 OVDI FAQs and noticed that the Service has refined and streamlined the voluntary disclosure process. Our firm prepared dozens of voluntary disclosure applications in 2009 and the new 2011
On February 8, 2011, the IRS announced the 2011 Offshore Voluntary Disclosure Initiative (OVDI), designed to bring offshore money back into the U.S. tax system and help people with undisclosed income from hidden offshore accounts
After a successful indictment of a New Jersey man with HSBC Bank accounts in India, the IRS introduced a new Voluntary Disclosure Program on February 8, 2011 for U.S. taxpayers with undisclosed offshore accounts. Last
HSBC, one of the largest banks international banks in the world, is facing rough time with allegations on its holding bankers being involved with a New Jersey Indian American businessman in hiding his bank accounts
The IRS...described the new program as “somewhat similar” to the prior program.
clients with a foreign HSBC account should be seriously concerned about disclosure of the account to the government, which could result in criminal prosecution and significant civil penalties.
