Eleven foreign financial institutions to share their US customer account information

- By : Parag Patel

…7. Bank Leumi Le-Israel 8. Bank Hapoalim 9. Mizrahi-Tefahot Bank 10. Liechtensteinische Landesbank 11. Neue Zuercher Bank (NZB) The terms of the US government agreement would be similar to the…

With No More Amnesty Program: Explore the IRS’s Traditional Voluntary Disclosure program

- By : Parag Patel

…criminal investigations. Parag Patel of Patel Law Offices believes that recent developments with investigations into prominent private offshore wealth management banks, regional – or cantonal – Swiss banks, as well…

Another foreign bank customer found guilty of foreign income under-reporting and FBAR violations.

- By : Parag Patel

…secret foreign bank accounts. Dr. Arvind Ahuja of Wisconsin was convicted earlier this week by a jury on federal tax charges stemming from his failure to disclose offshore bank accounts…

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 Launches Second Offshore Voluntary Disclosure Initiative After Successful Prosecution

- By : Parag Patel

After a successful indictment of a New Jersey man with HSBC Bank accounts in India, the IRS introduced a new Voluntary Disclosure Program on February 8, 2011 for U.S. taxpayers…

Watch Out for Letters From Your Foreign Bank Requesting Information On Your U.S. Residency

- By : Parag Patel

…already registered the United States government to share their U.S. customer. Some examples of foreign banks’ FATCA compliance include: Scotia Bank, Deutsche Bank, Bank of China, and thousands of other…

New IRS Voluntary Disclosure Program lets employers who received questionable Employee Retention Credits pay them back

- By : Parag Patel

…fully pay the amount due. This is entirely different and unique to this program. All other IRS voluntary disclosure programs previously charged penalties even if paid in full. Program participants…

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

- By : Parag Patel

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

US Government Continues to Pressure Swiss Banks

- By : Parag Patel

…USD780 million fine in 2009 for helping US citizens evade taxes, the Department of Justice has been pursuing other Swiss banks that it believes committed similar offences. Credit Suisse Group…

HSBC and NRI Bank Accounts: Could It Spread to Other Banks?

- By : Parag Patel

…move has raised several questions. First, why did US authorities single out HSBC? Second, would US IRS also approach banks like State Bank of India and Citibank for information? Responding…

New York Penalty and Interest Discount (PAID) program

- By : Parag Patel

…old are not eligible under this program.The program will start January 15, 2010. To take advantage of the program’s savings, eligible taxpayers must make all payments by the program’s expiration…

New Jersey Tax Amnesty program

- By : Parag Patel

Today the New Jersey Division of Taxation announced the launch of their Tax Amnesty program. The program is intended to provide individuals and businesses with the opportunity to pay back…

IRS examines jewelry, precious stones and metals businesses for compliance

- By : Parag Patel

…Laundering Programs. Who is subject to the Anti-Money Laundering Program requirements? Generally speaking, a jewelry business is subject to the Anti-Money Laundering Program requirement if two conditions are present (i)…

Received a FATCA Letter from Your Foreign Bank?

- By : Parag Patel

If you have any US connections and have a non-U.S. bank account, you may have recently received a letter from your bank asking for your tax information. This may seem…

Fifth HSBC India Customer indicted for tax evasion this year

- By : Parag Patel

…Sullivan and Trial Attorney Melissa S. Siskind of the Justice Department’s Tax Division. Mr. Sullivan, who has also previously prosecuted several other Swiss bank customers, is leading prosecutions in numerous…

IRS expands use of Subpeonas

- By : Parag Patel

…Kingdom. In the same year, similar orders were issued against Bank of New York (Mellon) and Citibank for the correspondent accounts of Swiss bank Zurcher Kantonalbank, against UBS for the…

Run to the Door: IRS Terminates Offshore Voluntary Disclosure Program (OVDP) effective September 28, 2018

- By : Parag Patel

…will begin to ramp down the 2014 Offshore Voluntary Disclosure Program (OVDP) and close the program on Sept. 28, 2018. By alerting taxpayers now, the IRS intends that any U.S….

All the Many FBAR Late Filing Procedures

- By : Parag Patel

program. To learn more about SFOP go to:  https://patellawoffices.com/blog/planning-for-tax-minimization/details-of-the-streamlined-foreign-offshore-procedures-sfop/ IRS Voluntary Disclosure Program Between 2009 to 2018 there used to be a program called the Offshore Voluntary Disclosure Program for…

The Tax Heat is On

- By : Parag Patel

…permit the IRS to seek records of the Belize Banks’ correspondent accounts at Bank of America, N.A. and Citibank, N.A. Pursuant to the summonses, Bank of America and Citibank have…

HSBC Bank Expects Significant Penalties from US Government for Violations

- By : Parag Patel

…of the ongoing “regulatory and law enforcement investigations”, along with the bank’s first quarter results. About the case involving its Indian unit, the banking giant said that HSBC Bank USA…

National Taxpayer Advocate Delivers Annual Report to Congress that Criticizes Offshore Voluntary Disclosure Programs

- By : Parag Patel

Program Inequities. The report describes the evolution of the OVD program and the disproportionate penalties it says were often imposed, particularly with respect to unrepresented taxpayers. The IRS changed the…

IRS Announces Major New changes to the Offshore Voluntary Disclosure Program

- By : Parag Patel

…are announcing today, we provide additional flexibility in key respects while maintaining the central components of our voluntary programs.” Balanced against the modified programs is the government’s ongoing effort to…

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

- By : Parag Patel

Foreign bank account reports (FBARs) for 2010 are due on June 30, 2011 (and no extension is available). Recent guidance provides insight into who is required to file an FBAR…

IRS Collects $10 Billion From Voluntary Disclosures of Foreign Assets

- By : Parag Patel

…to come to the IRS as a result of the Justice Department’s Swiss Bank Program, the IRS noted. As part of a series of non-prosecution agreements with banks such as…

One Month Countdown: The Deadline is Nearing for U.S. Taxpayers with Undisclosed Accounts to Come Forward

- By : Parag Patel

…clear up back taxes is expected to bring many out of the woodwork. Recently, the U.S. Department of Justice opened a formal investigation into the banking practices of another Swiss

Tax-free Disaster Relief Payment Program

- By : Parag Patel

…or program to inform employees of the availability and parameters of such a payment program. Any policy adopted by an employer in response to Section 139 should clearly document the…

Article Discusses Termination of Offshore Voluntary Disclosure Program (OVDP) and the Streamlined Filing Compliance Procedures (SFCP)

- By : Parag Patel

…the disclosure of foreign assets. One option is the Offshore Voluntary Disclosure Program (OVDP). Another is the Streamlined Filing Compliance Procedures (SFCP). SFCP is further bifurcated into two sub-programs—one for…

Instructions for New Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer U.S. Taxpayers

- By : Parag Patel

…not be accepted in this program. The only amended returns accepted through this program are those being filed for the sole purpose of submitting late-filed Forms 8891 to seek relief…

IRS Releases Training Documents on Offshore Voluntary Disclosure Program

- By : Parag Patel

…material used in training IRS personnel in the Offshore Voluntary Disclosure Program, determining program penalties and instructing IRS employees about the program. The purpose of the OVDP is for individuals…

HSBC Customer Avoids Jail in Tax Evasion Case

- By : Parag Patel

…talking with a banker in Fremont and asked if the bank would issue 1099 forms, according to the document. The banker stopped speaking in English and said in Hindi that…