2018 ABA COMMENTS ON THE OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS

- By : Parag Patel

…Streamlined Domestic Offshore Program (“SDOP”), and the Streamlined Foreign Offshore Program (“SFOP”). We co-authored the ABA comments. The comments are very constructive. It is hoped that the IRS carefully considers…

Government Report Advises IRS to Increase Awareness of Offshore Account Rules to Help Immigrants

- By : Parag Patel

…having offshore accounts, and more than half of them had accounts at Swiss bank UBS. Tax evasion by individuals with unreported offshore financial accounts was estimated by one IRS commissioner…

Another HSBC Customer Likely Going to Jail

- By : Parag Patel

…the private banking division; U.K. Banker A, a “high-ranking executive” in London and head of a cross-border banking group focusing on clients with ties to south Asia; and Swiss Banker…

IRS’ Takes Legal Action Against Offshore HSBC Indian Accounts

- By : Parag Patel

bank accounts in India. The legal action comes after the indictment of a New Jersey Indian American businessman in hiding his bank accounts in India from the Internal Revenue Service….

Fifth HSBC India Customer indicted for tax evasion this year

- By : Parag Patel

…taxpayers throughout the U.S. and around the world with undisclosed offshore accounts, believes that the recent indictments and large penalties should encourage more U.S. taxpayers with undisclosed offshore accounts, especially…

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

- By : Parag Patel

…Ltd. • Wegelin & Co. • Liechtensteinische Landesbank AG • Zurcher Kantonalbank • Swisspartners • CIBC FirstCaribbean International Bank Limited, its predecessors, subsidiaries, and affiliates • Stanford International Bank, Ltd.,…

Taxpayers’ Evidence of Non-Willfulness or Willfulness Factors

- By : Parag Patel

…above questions, did the taxpayer affirmatively tell the accountant or tax return preparer about the existence of any offshore accounts, offshore assets, or foreign source income? — failure to seek…

Another U.S. taxpayer with an offshore HSBC bank account pleads guilty

- By : Parag Patel

…include a Schedule B reporting her interest in or signature authority over foreign financial accounts at HSBC India. In 2008, Bhasin’s bank accounts at HSBC India were valued at approximately…

New IRS Subpoenae and IRS Data Mining Expected

- By : Parag Patel

…taxpayers, bankers, and other professionals who are involved in the world of offshore bank accounts. Given the IRS’ latest data mining efforts, our law firm expects unabated aggressive enforcement of…

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

- By : Parag Patel

Yesterday the Internal Revenue Service opened its Offshore Voluntary Disclosure Program (OVDP) to encourage more taxpayers with assets in undeclared foreign bank accounts to come forward. While the OVDP was…

Another Taxpayer Found Guilty of Failure to File FBARs and Report Foreign Income

- By : Parag Patel

…existence of Clariden Bank and Goldman, Sachs & Company Bank-Singapore accounts and the income earned in these accounts to his tax preparers for the years 2006 and 2008. The indictment…

New Court Ruling: FBAR penalties applied per form and not per account

- By : Parag Patel

The FBAR rules require the filing of a FinCEN Report 114, Report of Foreign Bank and Financial Accounts (FBAR) to report for accounts of U.S. persons aggregating $10,000 or more….

Another Swiss Bank Discloses Customer Names to the US

- By : Parag Patel

…Justice’s Swiss Bank Program. Swiss private bank BSI SA avoided prosecution for suspected tax-related offenses by paying a $211 million penalty, becoming the first bank to reach a deal in…

HSBC Customer Avoids Jail in Tax Evasion Case

- By : Parag Patel

…penalties, and disclosing offshore accounts and bankers. Dahake’s cooperation “revealed many others that were involved in acting in a similar fashion in a very large scheme involving these undeclared bank

HSBC Client Pleads Guilty to Conspiring to Hide Indian Accounts From IRS

- By : Parag Patel

…Services that marketed offshore banking services to U.S. citizens of Indian descent. Through NRI, the bank “encouraged U.S. citizens to open undeclared bank accounts in India,” according to the indictment….

Hiding Money or Income Offshore Among the “Dirty Dozen” List of Tax Scams for the 2015 Filing Season

- By : Parag Patel

…Income Offshore Over the years, numerous individuals have been identified as evading U.S. taxes by hiding income in offshore banks, brokerage accounts or nominee entities and then using debit cards,…

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

- By : Parag Patel

…result of this probe. Taxpayers are ineligible to participate in the IRS’s offshore voluntary disclosure program (OVDP) for undeclared offshore accounts if U.S. authorities already have their names. The program…

The IRS Large Business and International division (LB&I) has announced a new Post OVDP Compliance enforcement campaign

- By : Parag Patel

offshore bank accounts, as a result, they suggested the campaign. The IRS Post OVDP Compliance enforcement campaign goal is to improve return selection, identify issues representing a risk of non-compliance,…

Avoiding and Defining Willfulness

- By : Parag Patel

…not disclose such offshore accounts and assets. In addition, many U.S. taxpayers, both domestic and international, are facing pressure from foreign banks to disclose their U.S. taxpayer status (via FATCA…

Internal Revenue Service again issues annual reminder to US persons to report foreign accounts and foreign income

- By : Parag Patel

…the existence of foreign accounts, such as bank and securities accounts, and usually requires U.S. citizens to report the country in which each account is located. More information on the…

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

- By : Parag Patel

Offshore” written in red to indicate that the returns are being submitted under these procedures. – A fully executed Certification for Streamlined Foreign Offshore Procedures. Since the IRS asks for…

IRS Announces Major New changes to the Offshore Voluntary Disclosure Program

- By : Parag Patel

…include a new set of Offshore Voluntary Disclosure Program Frequently Asked Questions and Answers. “This opens a new pathway for people with offshore assets to come into tax compliance,” said…

HSBC Bank Expects Significant Penalties from US Government for Violations

- By : Parag Patel

…by entering the IRS amnesty program (OVDI/OVDP) in which they paid back taxes and penalties while disclosing the banks and bankers who helped them hide offshore accounts. Patel Law Offices…

Foreign bank account reports (FBARs) and the 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI)

- By : Parag Patel

…voluntary disclosure program for U.S. persons with unreported foreign financial accounts and other foreign assets. The 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI) is based on a similar voluntary disclosure…

New Leak of Offshore Accountholders Highlights the Need to Clean Up

- By : Parag Patel

…a penalty equal to 27.5 percent of the high value of the accounts. The IRS updated its list of foreign banks where accounts trigger a 50% (rather than 27.5%) penalty…

How Will the IRS Find Out By Your Foreign Account? Let’s Count the Dozens of Ways

- By : Parag Patel

…withdrawals. 2. IRS Investigations of numerous banks, including Credit Suisse, Julius Baer, HSBC, Basler Kantonalbank, Bank Leumi, Bank Hapoalim, and numerous others. The banks were required to disclose of your…

HSBC Expected to Disclose Account Holders Names

- By : Parag Patel

…net worth Indian US residents who maintain at least $100,000 in their bank accounts in HSBC India but only 1,921 of them have disclosed details of their accounts. In a…

A solution in a tough tax season: the IRS Streamlined Offshore Procedures

- By : Parag Patel

…file under the Streamlined Domestic Offshore Procedures (SDOP) or the Streamlined Foreign Offshore Procedures (SFOP). Our firm has recently received many inquiries regarding these new IRS Streamlined Offshore Procedures. These…

2011 Offshore Voluntary Disclosure Initiative (OVDI)

- By : Parag Patel

…account balance in the taxpayer’s foreign bank accounts during the years 2003 through 2010. This offshore penalty is in lieu of all other penalties that might apply, except for the…

New IRS guidance Announced for IRS Streamlined Offshore Procedures.

- By : Parag Patel

…file under the Streamlined Domestic Offshore Procedures (SDOP) or the Streamlined Foreign Offshore Procedures (SFOP). Our firm has recently received many inquiries regarding these new IRS Streamlined Offshore Procedures. These…