Analysis of the new 2012 Offshore Voluntary Disclosure Program (OVDP)

- By : Parag Patel

…the IRS’s ongoing well-publicized efforts with the Justice Department to pursue criminal prosecution of international tax evasion. Last year they charged a half dozen Americans with HSBC accounts with tax…

Significant FBAR Penalties Upheld by Court

- By : Parag Patel

…The taxpayer, Alice Kimble, held Swiss accounts at both HSBC and UBS in the early 2000s and was not aware until 2008 that she was required to report them to…

Another Bank Discloses Accountholders: Credit Suisse to Turn Over U.S. Account Data

- By : Parag Patel

…attorneys and at least 36 U.S. taxpayers. It is predicted that other Swiss and many other banks (including HSBC) under investigation will eventually settle with the U.S. For U.S. citizens…

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

- By : Parag Patel

…two biggest banks, and London-based HSBC Holdings Plc, Europe’s biggest bank. At least 21 bankers, advisers and attorneys also have been charged. The charges appear to be just the beginning…

What if You Missed the OVDI Deadline?

- By : Parag Patel

…taxpayer (or a related party), and before the government has received information from a third party (i.e., HSBC bank subpoena) about the taxpayer’s noncompliance. In essence, a voluntary disclosure is…

US Department of Justice Encourages Swiss banks to Disclose Information

- By : Parag Patel

…wife and two adult children maintained bank accounts worth more than $7 million with The Hongkong and Shanghai Banking Corporation Ltd. (HSBC) in India. Desai prepared and filed income tax…

More Swiss Banks Agree to Disclose US Customers Accounts: Expect More Customer Letters to be Sent

- By : Parag Patel

…Justice Department make up category 1 and aren’t included in the voluntary disclosure program. These include Credit Suisse Group AG, Julius Baer Group AG and the Swiss branch of HSBC

Foreign Account Penalties Are Unfair

- By : Parag Patel

Our office is advising dozens of clients (including many HSBC customers) regarding offshore accounts, all of whom may be subject to large unfair penalties. Finally it appears that someone in…

For the First Time IRS Issues Information on 2011 Offshore Voluntary Disclosure Initiative (OVDI) in Hindi Language

- By : Parag Patel

In an effort to reach all taxpayers, including those ensnared in the pending HSBC subpoena to disclose customer names of non-resident indian customers with offshore accounts, the IRS has published…

New IRS Subpoenae and IRS Data Mining Expected

- By : Parag Patel

…& Legal Ltd. for offshore accounts and assets. They include Western Union Financial Services Inc., the Federal Reserve Bank of New York, Clearing House Payments Company LLC, and HSBC USA….

IRS expands use of Subpeonas

- By : Parag Patel

…of U.S. authorities to offshore banks. In 2013, the IRS issued John Doe summonses against Bank of New York (Mellon), Citibank, JPMorgan Chase, HSBC and Bank of America to produce…

Common Issues for US-India Tax Reporting

- By : Parag Patel

…term over one year must be given OID treatment; interest is taxed when accrued, not earned. Indian life insurance is typically non-qualified and must receive 7702G computations. HSBC India is…

New voluntary disclosure program for offshore accounts in 2011

- By : Parag Patel

…actions, one being another well-known Swiss bank and one being an Asian bank (HSBC). One thing is clear, the mere fact that a taxpayer’s bank has not yet been the…

How to Defend Against FBAR Penalties

- By : Parag Patel

…taxpayers who are not in compliance—from the offshore voluntary compliance submissions submitted (which often leads to other taxpayers and advisors thereto) and from banks such as UBS and HSBC who…

Bank Leumi: Another Foreign Bank Recommends the IRS Voluntary Disclosure Program

- By : Parag Patel

…reference to the offshore voluntary disclosure program. The bank also gave a hotline for clients. Certain foreign branches of HSBC bank have also recently sent out a similar letter to…

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

- By : Parag Patel

…the list may grow as FATCA is implemented, the current list of those banks include: HSBC India • UBS AG • Credit Suisse AG, Credit Suisse Fides, and Clariden Leu…

2 recent IRS developments that will impact Indian Americans

- By : Parag Patel

…tax return with the IRSwhere he failed to report the interest income earned on bank deposits at HSBC India. Second, he did not file an FBAR (Foreign Bank and Financial…

The “Quiet” or “Silent” Disclosure

- By : Parag Patel

…any HSBC (or any XYZ) bank account that starts with “140″ (or known prefix) was opened between 2001 and 2003. This could initiate a civil audit or criminal investigation. The…

Eleven foreign financial institutions to share their US customer account information

- By : Parag Patel

…be dropped. The eleven financial institutions are: 1. Credit Suisse (including Clariden Leu) 2. HSBC Holdings 3. Basler Kantonalbank 4. Wegelin & Co 5. Zuercher Kantonalbank 6. Julius Baer Group…

IRS Announces New 2012 Offshore Voluntary Disclosure Program (OVDP)

- By : Parag Patel

…these taxpayers may come into compliance with U.S. tax law.” In light of the numerous probes and summonses against several foreign banks, including HSBC, it is imperative that U.S. accountholders…