Search Results for: voluntary disclosure programs
Taxpayers Advised to Use Caution: Confirmed FBAR Information Request Scam
…purportedly from the IRS Chief of Criminal Investigations, indicating there are issues with their filing and requesting disclosure of all their “domestic and international financial accounts.” The notice instructs the…
Beware: India to sign FATCA agreement with US for sharing of information
…clients to expect the unexpected (and the worst) in their tax treatment and disclosure of offshore assets, particularly for Indian assets. The fact that 77,000 banks have registered and over…
Checklist of tax forms for taxpayers with foreign assets
…US tax laws, including increased criminal prosecutions and civil audit examinations. We have been advising our clients to expect the unexpected (and the worst) in their tax treatment and disclosure…
How to Benefit from Tax Treaties
…other countries. Form 8833, the Treaty-Based Return Position Disclosure Under Section 6114 or 7701(b) is the form may have to file if you wanted to claim certain tax treaty benefits…
Consequences of Filing False Streamlined Filings
…three years in prison. These cases show that taxpayers should be very careful in making a complete and correct Streamlined disclosure to the IRS. Advisors counseling taxpayers on Streamlined Procedures…
Becoming Un-American: Record number of US citizens renounce their US citizenship
…FATCA requires individuals to report certain foreign assets and banks to disclose all foreign accounts held by Americans. Key FATCA disclosure rules take effect this year that will make avoiding…
Asset Protection
…litigation. Whether or not litigation ever arises, a client may face difficult decisions each year when the client’s Form 1040; full disclosure on a return is inconsistent with planning based…
FATCA Deadlines Extended
Many of our tax-noncompliant clients are fearful of being involuntary discovered through the impending FATCA disclosures of their foreign accounts by their foreign banks. The Internal Revenue Service has issued…
How to Demonstrate Non-Willfulness Under The Streamlined Filing Compliance Procedures
…from a firm under U.S. pressure to another, presumably to avoid disclosure; making large cash withdrawals; instructing a firm not to mail statements to the U.S., or communicating in code…
India and US signed FATCA Agreement Today
…disclosure of offshore assets, particularly for Indian assets. Patel Law Offices has consulted with hundreds of clients regarding their offshore asset compliance issues. Patel Law Offices is a law firm…
India Expected to Sign FATCA Agreement Tomorrow
…the worst) in their tax treatment and disclosure of offshore assets, particularly for Indian assets. The fact that 77,000 banks have registered and over 100 countries will be providing government…
Mediating Probate Disputes
…of the public record. The mediator usually asks the parties to sign an agreement not to disclose information conveyed during the mediation. In addition, state law generally limits the disclosure…
2012 Offshore Account Criminal Tax Cases
…tax laws, including increased criminal prosecutions and civil audit examinations. We have been advising our clients to expect the unexpected (and the worst) in their tax treatment and disclosure of…
Do You Have to Pay US Taxes on Foreign Inheritance?
…investments are bought or sold. A PFIC requires complex reporting on Form 8621. In addition to the complex reporting of investments in these accounts, disclosure of these accounts is required…
India Signs FATCA Model Intergovernmental Agreement to Share Account Information with the US
…US tax laws, including increased criminal prosecutions and civil audit examinations. We have been advising our clients to expect the unexpected (and the worst) in their tax treatment and disclosure…
Foreign Account Tax Compliance Act – Traps for the Unwary
…disclosure form there’s no SOL on assessment (making it akin to the current situation for fraud). That’s true even if the IRS knows you’ve got the asset(s) because they notified…
Form 8938, FATCA, FBAR and penalties for all (including bankers)
…have been advising our clients to expect the unexpected (and the worst) in their tax treatment and disclosure of offshore assets. Patel Law Offices is a law firm dedicated to…
What is the U.S. tax on Inheritances from a Non-U.S. Person to U.S. Person?
…The amount and description of the bequest must be disclosed on Form 3520, but the IRS does not require disclosure of decedent or donor’s identity. The IRS is mostly concerned…