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Category: Planning for Tax Minimization

Fifth HSBC India Customer indicted for tax evasion this year

19 November, 2011

A federal grand jury in San Jose, California, last week indicted Ashvin Desai of San Jose on three counts of tax evasion, two counts of willfully aiding the preparation of materially false tax returns and

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The Risks of “Opting Out” of OVDI

29 October, 2011

Under the 2011 OVDI voluntary disclosure program, the penalties for failing to timely file Foreign Bank Account Reports, (FBAR’s) and the penalties for failure to file information returns (such as Controlled Foreign Corporation tax returns)

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Taxpayers Advised to Use Caution: Confirmed FBAR Information Request Scam

25 October, 2011

Our firm has become aware of a “phishing” scam, related to the filing of Report of Foreign Bank and Financial Accounts (FBAR). Under the scam, taxpayers receive an email notice, purportedly from the IRS Chief of

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Another Foreign Bank Charged by U.S. Department of Justice

15 October, 2011

Earlier this week, two Julius Baer Group Ltd. client advisers were charged with helping U.S. customers of the Zurich- based bank evade taxes, according to an indictment and a person with knowledge of the matter.

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What if You Missed the OVDI Deadline?

7 October, 2011

Although the OVDI program has expired, a U.S. taxpayer can still make a voluntary disclosure of foreign accounts pursuant to the IRS’s general voluntary disclosure policy. For over 50 years, the IRS has maintained a

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HSBC India Customer New Indictment Uncovers More HSBC Details

29 September, 2011

A Wisconsin neurosurgeon was re- indicted by a U.S. grand jury on new charges that he failed to declare an HSBC Holdings Plc (HSBA) account in India valued in 2009 at $8.7 million.  Arvind Ahuja

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Employee or Contractor?: The IRS’s New Voluntary Classification Settlement Program (VCSP)

28 September, 2011

When the IRS says “voluntary” it can sound scary. The IRS is unlikely to use this word unless the potential liability is serious. The IRS would much rather have you come forward. If you do,

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For Tax Professionals: A Guide to the IRS’s Voluntary Disclosure Practice

19 September, 2011

IRS Commissioner Shulman has invited persons with unreported foreign accounts to come forward and avail themselves of the IRS’s Voluntary Disclosure Practice. That practice is described in the Internal Revenue Manual 9.5.11.9. The Practice has

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IRS Publicizes and Celebrates OVDI Success

16 September, 2011

As expected, the United States Internal Revenue Service (IRS) has disclosed that the recently-completed offshore voluntary offshore initiative (OVDI) has pushed the total number of voluntary disclosures up to 30,000 since 2009. The IRS customarily

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With No More Amnesty Program: Explore the IRS’s Traditional Voluntary Disclosure program

14 September, 2011

Even though the deadline for the Internal Revenue Service’s 2011 Offshore Voluntary Disclosure Initiative has concluded last week, U.S. taxpayers with undisclosed offshore accounts still have the opportunity to come forward through the IRS’s traditional

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New Extended Deadline for OVDI

30 August, 2011

Last week, late on Friday afternoon, August 26, 2011, the IRS issued a statement indicating that the due date for filing 2011 Offshore Voluntary Disclosure Initiative (OVDI) requests has been extended until September 9, 2011,

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Audit Beware: IRS’ Global High Wealth Industry Group

18 August, 2011

A recent article in the Wall Street Journal discussed the new IRS’ Global High Wealth Industry Group. Over 1 year ago we warned readers of the new group when Commissioner Shulman announced its formation in

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