Search Results for: offshore bank accounts
The IRS has woken up.
…in 2018 or previous years.” 3. Offshore Tax Evasion. The IRS Commissioner last month again verified that offshore tax reporting enforcement remains one of the IRS’s absolute top priorities. He…
Top 10 factors to consider before deciding to opt out of OVDI or OVDP
…you have other issues that can be discovered then OVDI (which typically focuses only on offshore asset/income issues) may be preferred. 9. Your confidence in your tax attorney. Experience matters….
New FBAR Court Case Makes it Easier for Taxpayers to be Deemed Willful
…recent decision by the IRS to end the Offshore Voluntary Disclosure Program on September 28, 2018. Taxpayers who wish to join the OVDP need to make complete offshore voluntary disclosures…
Opt Out of OVDI Program Penalties to Get a Lower Penalty
Under the 2011 Offshore Voluntary Disclosure Initiative (OVDI) or 2012 Offshore Voluntary Disclosure Program (OVDP), the 2012 program gives no discretion to the IRS agents to reduce penalties. If a…
Opting-out or Opting-in of OVDI
…could be proved to not be “wilful”, and has also re-specified the conditions under which taxpayers making voluntary disclosures may qualify for a 5% offshore penalty. For example, that reduced…
Top 5 tax fraud recoveries in 2022
…criminally disregarded this requirement. He earned over $66 million from his work, but used sophisticated offshore structures, trusts, and bank accounts to conceal that income, and did not file returns…
Educational Panel Discussion: The U.S. Government’s Global Crackdown on Tax Evasion: Where It Has Been and Where It Is Going
…regarding some details of the US DOJ Program for Swiss Banks. She said that the information received from US DOJ Program for Swiss Banks and OVDP will lead to new…
FBAR statute of limitations court case ruling
…Bank Account Reporting, or FBAR forms from 2006 through 2008. The court held that the Internal Revenue Service could not go back beyond the general three-year limitations period. FBAR requirements…
Beware of U.S. tax consequences to a foreign trust with a U.S. beneficiary
…and an interest charge. Report of Foreign Bank and Financial Accounts (“FBAR”) Filings: FBAR filings on Form TD-F 90-22.1 are generally required to be made by U.S. persons who have…
IRS Passport Revocation or Denial for Unpaid Taxes
…country where you reside, so you usually don’t have to worry about double taxation. The IRS also requires taxpayers to report any amounts over $10,000 in foreign accounts, and failure…
New Comments of the IRS’ New Streamlined Filing Compliance Procedures for Non-Resident Non-Filer U.S. Taxpayers
…offshore accounts should nonetheless apply to the program if they are low-risk account holders. – The streamlined program, introduced August 31, was meant as a way to allow low-risk, noncompliant…
New Law’s Reporting Requirements Make It Very Likely That the IRS Will Now Know About Your Foreign Account
Under the recently enacted Foreign Account Tax Compliance Act (“FATCA”), foreign financial institutions (“Financial institutions” is broadly defined to include banks, mutual funds, funds of funds, exchange-traded funds, hedge funds,…
The Tax Issues of Expatriation
…apply to the following. Eligible deferred compensation items. Ineligible deferred compensation items. Interests in nongrantor trusts. Specified tax deferred accounts. Instead, items (1) and (3) may be subject to withholding…
Delinquent or unfiled IRS Form 5471
…of foreign (non-U.S.) financial accounts and their related incomes. Beware: As of January 1, 2009, the IRS began to automatically assert the $10,000 penalty on late filed Forms 5471. Due…
New FATCA / CRS reporting penalties in India
…institutions is made annually, the penalty of Rs. 5000 will also be levied every year. The penalty can be very large for someone who has 5 bank accounts, 10 mutual…
National Taxpayer Advocate calls IRS Penalties Draconian and Inefficient
…the burden to establish willfulness by clear and convincing evidence before asserting a civil willful Report of Foreign Bank and Financial Accounts (FBAR) penalty and that the government cannot meet…
Estate Planning in New Jersey
…trusts Gifting cash or other assets before your death “Transfer On Death” (“TOD”) or “Payable On Death” (“POD”) bank accounts Holding assets by joint tenancy with right of survivorship (“JTROS”),…
IRS Reduces Administrative Burden (for the first time) of Filing Some Forms 3520 and/or Forms 3520-A
…Foreign Bank and Financial Accounts (FBAR). Taxpayers who have not filed to file any such international forms should seek competent legal counsel immediately to avoid or reduce the high penalty…
Estate Planning Discussions: difficult, emotional and stressful
…may want to make available (perhaps to a trusted family member) the details and location of their financial accounts. These would include the location of bank, brokerage, and credit card…
Taxpayers Advised to Use Caution: Confirmed FBAR Information Request Scam
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,…
Canada and US sign FATCA tax deal where banks to share information with IRS
…on the automatic sharing of bank information between the two countries as part of efforts to battle tax evasion. On February 5, 2014, the Canadian government announced that it has…
The Expensive NJ Inheritance and Estate Tax
…may be used to secure the release of bank accounts, stocks, bonds and brokerage accounts and Form L-9 may be used to secure the release of the State’s lien on…
Watch Out: The NJ Inheritance Tax
…secure the release of bank accounts, stocks, bonds and brokerage accounts and Form L-9 may be used to secure the release of the State’s lien on real property owned by…
New Jersey inheritance tax
…no inheritance tax return is required to be filed for Class A beneficiaries, Form L-8 may be used to secure the release of bank accounts, stocks, bonds and brokerage accounts….
Information Sharing of Account Holder Information Officially Begins
…failed to report income, bank accounts, corporations, trusts or other assets outside the U.S. are increasingly at risk of being detected, fined and in some cases prosecuted. It is strongly…
New IRS internal procedure guidance for Streamline Filing Compliance Procedures
The IRS has published new IRS internal procedure guidance with IRM changes dated 8/13/14. The guidance is numbered WI-21-0814-1244 and titled “Streamline Filing Compliance Procedures for Accounts Management International IMF”….
IRS Announces new OVDP Declines-Withdrawals Campaign
…the IRS Offshore Voluntary Disclosure Program. Entitled, “OVDP Declines-Withdrawals Campaign,” this area of focus involves taxpayers who have applied for the offshore voluntary disclosure program through the pre-clearance process, but…
IRS Aggressively Starts New Criminal Investigations
…taken up by the Criminal Investigation division. The IRS is also escalating enforcement efforts around unlawful offshore tactics, specifically targeting Maltese personal pension plan schemes. In June, the IRS and…
Dormant foreign corporations not subject to complicated Form 5471 filing requirements
…correct many Form 5471 errors. If you have any further questions about your reporting requirements on this, or any other offshore reporting form, contact us online to schedule a free…