Search Results for: international tax
Dormant foreign corporations not subject to complicated Form 5471 filing requirements
…firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and their advisors to legally disclose (and legitimize) foreign assets….
Cost of Compliance Rises under OVDP
…Corporate Services Inc. (effective 11/15/16) IPC Corporate Services LLC (effective 11/15/16) Titan International Securities, Inc. (effective 11/15/16) Legacy Global Markets S.A. (effective 11/15/16) Unicorn International Securities LLC (effective 11/15/16) Andrew…
IRS Official Provides Insights for the new IRS Streamlined Compliance Procedures
…a “voluntary, conscious and intentional” act by the taxpayer. Taxpayers considering the streamlined procedures should carefully review the recent court decisions in United States v. Williams, No. 10-2230 (4th Cir….
50% Penalty for Taxpayers Who Hold Accounts at a Bank Under Investigation
…taxpayers. The modifications greatly eased penalties for people who were unaware of tax and disclosure requirements. At the same time, the IRS sharply increased the penalty for people in its…
New Online System for Filing Your Report of Foreign Bank and Financial Accounts (FBAR)
…FBARs. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and their advisors…
Denied access to or withdrew from the IRS Offshore Voluntary Disclosure Program (OVDP)?
…responding can be extending by 60 days, if necessary. Taxpayers who receive Letter 5935 should consult with a tax attorney as soon as possible to determine the taxpayer’s best option…
IRS Targets Non-Resident Indians with HSBC Accounts
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…
New Comments on the IRS Voluntary Disclosure Program
…of taxpayers.” Individuals in the Section also received verbal requests from the Service for comments on employment tax issues under the VDP. We would like to thank the Service for…
Foreign Gift Received: Form 3520 Penalties Eliminated in New Court Case
…and Bittner cases may indicate a move by the IRS and Tax Division of the DOJ to show more leniency towards taxpayers who report failures to file international informational returns…
Swiss Bank Disclosure Round Up
…may have committed tax offenses, and are eligible for a non-prosecution agreement if they come clean and face fines. Banks which have said they will do so include: EFG International…
The Risks of “Opting Out” of OVDI
…(No.51 ) discusses the basis upon which a taxpayer might “opt out” of the offshore voluntary disclosure program. The IRS uses the term “reasonable cause” in defining whether a taxpayer’s…
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,…
IRS Announces new OVDP Declines-Withdrawals Campaign
…program. We have seen more audits and FBAR inquiries associated with taxpayers who have not come forward. Taxpayers should know whether they have Federal tax return issues, or anticipated issues,…
First Indictment for FATCA Violation Announced
Federal prosecutors charged six men Tuesday with running a complicated offshore scheme that allegedly enabled clients to manipulate stocks, avoid U.S. taxes and launder hundreds of millions of dollars. An…
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”….
Below is a List of Common Forms Applicable in Compliance Requirements for U.S. Citizens and Residents with Foreign Assets, Trusts, and Entities
Foreign Financial Assets FinCEN Form 105 Report of International Transportation of Currency or Monetary Instruments FinCEN Form 114 Report of Foreign Bank and Financial Accounts (FBAR) Form 8938 Statement of…
Beware of Currency Seizures
…money was seized because of a failure to report flying internationally with $10,000 or more. Reporting violations represented half of all seizures. Nearly 70% of seizures were not accompanied by…
IRS issues new information document request (IDR) directives
…the requests to taxpayers it is supposed to meet with those taxpayers and agree upon the kind of information covered under an IDR and determine an appropriate response date. Under…
Welcome news from IRS for late Form 3520 penalties
…sent informational letters to taxpayers that it determined might have delinquent Form 3520 or 3520-A filing requirements (see www.irs.gov). At some point in 2019, taxpayers started to observe that late-filing Forms 3520 or 3520-A, even with…