Page 14 – Tax, Estate Planning & Probate Law Center

IRS Official Provides Insights for the new IRS Streamlined Compliance Procedures

15 Aug 14

Taxpayers who are in the Offshore Voluntary Disclosure Program to report their overseas assets can request the favorable penalty structure under newly expanded streamlined compliance procedures without giving up the audit and criminal liability protection offered by the OVDP, according

How to Demonstrate Non-Willfulness Under The Streamlined Filing Compliance Procedures

11 Aug 14

The IRS recently announced Streamlined Filing Compliance Procedures in an effort to encourage U.S. taxpayers to come into compliance with their reporting and filing requirements associated with varying interests in foreign financial accounts and assets. The streamlined procedures require the

Taxpayer’s Beware: Proving Non-Willful Conduct in the new IRS Streamlined Filing Compliance Procedures

02 Jul 14

Taxpayers should think carefully before entering a new Internal Revenue Service program titled Streamlined Filing Compliance Procedures for offshore-account holders whose conduct was not “willful”. On June 18th, the IRS announced significant changes to its limited-amnesty programs for U.S. taxpayers

IRS announces new Streamlined Filing Compliance Procedures

30 Jun 14

The IRS announced substantial changes to both the Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer Taxpayers and the Offshore Voluntary Disclosure Program (OVDP) on June 18, 2014. Effective July 1, 2014, the IRS is making it easier for individuals to

50% Penalty for Taxpayers Who Hold Accounts at a Bank Under Investigation

21 Jun 14

The Internal Revenue Service announced last week changes to its programs for taxpayers with undeclared offshore accounts, the latest step in a five-year campaign against such accounts held by U.S. taxpayers. The modifications greatly eased penalties for people who were unaware

New IRS Disclosure Program Announced for Non-Resident Taxpayers: Streamlined Foreign Offshore Procedures

21 Jun 14

The United States’ IRS is moving to entice more taxpayers to disclose their unreported assets and income just weeks before implementation of the U.S. Foreign Account Tax Compliance Act (FATCA). The IRS has announced a Streamlined Foreign Offshore Procedures (SFOP),

IRS Announces Major New changes to the Offshore Voluntary Disclosure Program

18 Jun 14

The IRS today made significant changes to its offshore voluntary compliance programs, with the intent of providing new options to help both taxpayers residing overseas and those residing in the United States. The agency says the changes are anticipated to provide

New Streamlined Domestic Offshore Procedures (SDOP) is a Game Changer

18 Jun 14

The IRS has announced a Streamlined Domestic Offshore Procedures (SDOP), which will significantly alter all future voluntary disclosures. The SDOP is a game changer for residents and non-resident (who would use the Streamlined Foreign Offshore Procedures (SFOP)) taxpayers alike. The

FBAR Reporting Season is here

16 Jun 14

All taxpayers are reminded about FBAR reporting this year, as the process has changed. If you have a financial interest in or signature authority over a foreign financial account, including a bank account, brokerage account, mutual fund, trust, or other

New offshore voluntary disclosure program (OVDP) changes expected to be favorable to taxpayers

09 Jun 14

During Internal Revenue Service (IRS) Commissioner John Koskinen’s remarks at a speech before the United States Council-OECD International Tax Conference in Washington last week, he indicated that the agency is preparing a new offshore voluntary disclosure program (OVDP) that will

Swiss Banks’ Deadline to Disclose Information is Extended

09 Jun 14

The U.S. Department of Justice last Thursday issued a release stating that it extended for one month the deadline for so-called category two Swiss banks suspected of helping wealthy Americans evade taxes to turn over information by one month. We

FATCA-Compliant Institutions List Goes Online

03 Jun 14

While over 77,000 banks and financial institutions have registered under FATCA—the Foreign Account Tax Compliance Act, the Internal Revenue Service has introduced an online tool that will allow users to check on whether a foreign financial institution has registered for

US Government Continues to Pressure Swiss Banks

15 May 14

The US government is putting pressure on Switzerland to end its tradition of “banking secrecy”, as part of a global crackdown on tax evasion. Since forcing UBS to pay a USD780 million fine in 2009 for helping US citizens evade

FATCA Enforcement Softens

08 May 14

Realizing the large administrative burden of FATCA, the IRS has announced a “soft opening” of FATCA and enforcement at the IRS’ discretion for an initial transitional period. FATCA, which was signed in March 2010, requires foreign banks and other financial institutions

India Signs FATCA Model Intergovernmental Agreement to Share Account Information with the US

02 May 14

The U.S. Treasury announced that on April 11, 2014, India agreed “in substance” to sign a Model 1 FATCA Model Intergovernmental Agreement (IGA) with the US. The IGA would therefore require Indian financial institutions to report information on U.S. account holders to

IRS Reminds (again) Taxpayers to Report Foreign Income and Assets

30 Apr 14

Earlier this month on April 11, 2014, the Internal Revenue Service issued Notice IR-2014-52 reminding U.S. citizens and resident aliens, including those with dual citizenship who have lived or worked abroad during all or part of 2013, that they may have a

Most Swiss banks participating in the US Department of Justice (DOJ) amnesty program seek extension to disclose

28 Apr 14

By April 30, 2014, unless granted a 60-day extension, all Swiss banks participating in the US Department of Justice (DOJ) amnesty program will be required to provide substantial client information on its US account holders. We have previously posted on

IRS’ first-time penalty abatement administrative waiver (FTA)

24 Apr 14

12 years ago the IRS created the first-time penalty abatement administrative waiver (FTA), which allows typically compliant individual and business taxpayers to request abatement, or removal, of certain penalties that the IRS has assessed against them for the first time. In

IRS issues new information document request (IDR) directives

14 Apr 14

The IRS’ Large Business & International division has issued a series of directives that streamline its information document request (IDR) process by establishing stricter deadlines and requiring the agency to issue highly specific information requests. A copy of the IRS’

Cayman Islands Advisors Arrest Suggest U.S. Government Receiving More Information About Offshore Accounts

08 Apr 14

According to a DOJ Tax Press Release, here, the IRS has arrested a U.S. Citizen and two Canadian citizens who offered enabler services to U.S. taxpayers. They were caught in a classic IRS sting operation. Here is a summary of the

Tax treaty tie-breakers

26 Feb 14

Under many US tax treaties, if a foreign individual is a tax resident of both the US and his home country then certain ‘tie breaker’ rules will apply to determine tax residence for treaty purposes. Generally, the individual will be

Republican Party Rallies Against FATCA: Success Unlikely

22 Feb 14

The Republican Party is expected to approve a resolution calling for repeal of an Obama administration law that is designed to crack down on offshore tax dodging. In what would be the party’s first appeal to scrap the law -the

No More Delays for FATCA: Get Ready for Disclosure

13 Feb 14

The US Foreign Account Tax Compliance Act (FATCA) will definitely come into effect on 1 July this year with no possibility of further delay, according to officials of the US Internal Revenue Service (IRS). FATCA, which was signed in March

Canada and US sign FATCA tax deal where banks to share information with IRS

06 Feb 14

Ottawa and Washington have reached a compromise over how to apply a U.S. law targeting would-be American tax dodgers living in Canada. Canada has signed an agreement with the U.S. on the automatic sharing of bank information between the two

US DOJ Tax Asst Attorney General Keneally Reports that One third of Swiss Banks Joining US DOJ Swiss Bank Program

29 Jan 14

We have previously posted on the U.S. Justice Department’s program offered to Swiss banks and targeted to identifying U.S. taxpayers that have not disclosed foreign accounts to the IRS. It has now been stated that that one-third of all Swiss

Swiss Bank Disclosure Round Up

02 Jan 14

A host of Swiss banks have signaled their readiness to work with U.S. officials in a crackdown on wealthy Americans evading taxes. Many more are expected to follow in the coming weeks, as Switzerland’s cherished bank secrecy slowly gets wound back.

More Swiss Banks Agree to Cooperate with the IRS

31 Dec 13

Lombard Odier & Cie and VP Bank (Switzerland) last week became the latest Swiss banks to say they would work with U.S. officials in a crackdown on lenders suspected of helping wealthy Americans evade taxes through hidden offshore accounts. Unlisted

U.S. Signs FATCA Pacts with Malta, Netherlands, Bermuda, Jersey, Guernsey and Isle of Man

28 Dec 13

Last week, the U.S. signed six more intergovernmental agreements with a half dozen jurisdictions, including several traditional offshore tax havens, to implement the Foreign Account Tax Compliance Act, or FATCA. Over the past week, the U.S. Treasury Department has signed

Argue for No Penalty and a Warning Letter for FBAR Violations

22 Dec 13

The IRS may send a warning letter in lieu of asserting penalties for failure to file a Form TD F 90-22.1, “Report of Foreign Bank and Financial Accounts,” if it would be sufficient to bring the individual into compliance, an

Swiss Banks are Pressuring Customers to Disclose

21 Dec 13

Swiss banks are pressuring current and former U.S. account holders to disclose undeclared assets to the Internal Revenue Service. In some cases, the banks are freezing accounts unless clients can prove they have declared the account to the IRS—or that

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