Offshore Compliance Programs Generate $8 Billion; IRS Urges People to Take Advantage of Voluntary Disclosure Programs

- By : Parag Patel

…2009, the Internal Revenue Service today reminded U.S. taxpayers with undisclosed offshore accounts that they should strongly consider existing paths established to come into full compliance with their federal tax…

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…

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

- By : Parag Patel

…certain accounts held between 2002 and 2010, according to a November 2nd letter sent to a client by the bank. The IRS sought data for accounts owned through domiciliary companies…

HSBC officially provides information on clients having accounts in India to the US Department of Justice and IRS

- By : Parag Patel

…informed its American clients having bank account in HSBC India that IRS has served a summons on the bank seeking information with regard to financial accounts of US persons maintained…

Another Local New Jersey client of HSBC India Pleads Guilty

- By : Parag Patel

…Foreign Bank and Financial Accounts, or FBARs. HSBC’s Geneva-based private bank is one of at least 11 Swiss firms under investigation by U.S. prosecutors investigating offshore tax evasion. HSBC’s Swiss…

IRS Targets Non-Resident Indians with HSBC Accounts

- By : Parag Patel

offshore accounts with five bankers from a bank that has headquarters in England. The people familiar with the probe confirmed it to be the HSBC Bank. It was also said…

Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Foreign Offshore Procedures (SFOP)

- By : Parag Patel

…file under the Streamlined Domestic Offshore Procedures (SDOP) or the Streamlined Foreign Offshore Procedures (SFOP). This article focuses on the SFOP. The Internal Revenue Service (IRS) recently modified the non-willfulness…

New Unreported Offshore Assets case: Bad facts leads to bad results

- By : Parag Patel

…he stashed in secret accounts at Credit Suisse, its subsidiaries, and another Swiss bank. Kim deliberately violated the U.S. bank secrecy laws by failing to report his foreign financial accounts

Quiet or Silent Disclosure Commentary from the Government Accountability Office

- By : Parag Patel

…that would otherwise be owed in offshore programs by reporting the existence of any offshore accounts and any income from the accounts on their current year’s tax return, without amending…

The Misunderstood Extension of time to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)

- By : Parag Patel

…required to file an FBAR in the following year. Foreign financial accounts include bank accounts, brokerage accounts, mutual funds and other pooled investment funds at foreign financial institutions, including many…

Details of the Streamlined Foreign Offshore Procedures (SFOP)

- By : Parag Patel

Offshore Procedure (SDOP)”) and another track for taxpayers who reside outside the United States (hereinafter “Streamline Foreign Offshore Procedure (SFOP)”). The eligibility requirements for the separate tracks have some notable…

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…

President Trump Revamps the IRS through his 2019 Taxpayer First Act

- By : Parag Patel

…taxes but does not know his or her identity (e.g., holders of offshore bank accounts), it can issue a summons (a “John Doe summons”) to a bank or other third…

IRS Offshore Voluntary Disclosure Programs Continue to Burden “Benign Actors” and Damage IRS Credibility

- By : Parag Patel

…Government Accountability Office (GAO) analysis shows that the offshore penalty paid by those with the smallest accounts (i.e., those in the 10th percentile with accounts of $78,315) was disproportionate –…

FATCA Enforcement Softens

- By : Parag Patel

…the U.S. and around the world with undisclosed offshore accounts, believes that FATCA is a game-changer in international tax compliance. FATCA should encourage more U.S. taxpayers with undisclosed offshore accounts

What Happens to Your Digital Accounts In Case of Death

- By : Parag Patel

…include all of your online accounts including bank, investment, loan, insurance accounts, social media accounts, and email accounts. 2.          Share your account logins and other secure information with a password…

India and the US have agreed to collaborate on offshore tax evasion

- By : Parag Patel

…includes careful scrutiny of bank electronic databases, bank paper files of account records, and interviews of bank managers and relationship managers regarding customers’ foreign status. If a customer is deemed…

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 Court Case Limits the Reasonable cause exception to FBAR penalties

- By : Parag Patel

…File FBAR Forms? The United States Tax Code requires U.S. citizens and taxpayers with interest in foreign bank accounts or other financial accounts to file an annual report of those…

New Favorable Court Decision: One penalty (not multiple) applies for late FBAR filing

- By : Parag Patel

…filing of a single accurate “Report of Foreign Bank and Financial Accounts” (FBAR) that includes multiple foreign accounts. The Boyd case holds that the IRS may impose only one non-willful…

The FinCEN Files Leak

- By : Parag Patel

…clients with offshore bank accounts want to know if they can repatriate their funds to the U.S. without taking any affirmative steps such as a voluntary disclosure on the theory…

Top FBAR Reporting Error

- By : Parag Patel

The most common FBAR reporting mistake is simply failing to file. Some U.S. persons continue to deliberately conceal assets in secret offshore bank accounts in the hope of evading U.S….

In Addition to HSBC, Credit Suisse Also Being Investigated for Offshore Activities

- By : Parag Patel

…which is likely, it may be too late for U.S. taxpayers with undisclosed HSBC accounts to take advantage of the IRS Voluntary Disclosure Program for offshore accounts. The IRS says…

New Online System for Filing Your Report of Foreign Bank and Financial Accounts (FBAR)

- By : Parag Patel

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) on Monday said it has developed an electronic filing system for Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts

IRS Announces New 2012 Offshore Voluntary Disclosure Program (OVDP)

- By : Parag Patel

The Internal Revenue Service today reopened the offshore voluntary disclosure program to help people hiding offshore accounts get current with their taxes. The IRS reopened the Offshore Voluntary Disclosure Program…

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

- By : Parag Patel

…Financial Accounts (FBAR)) to enter into an offshore voluntary disclosure (OVD) settlement program and pay an “offshore penalty” designed for bad actors. “Benign actors” with inadvertent violations generally had to…

IRS Official Announces New Focus on Offshore Assets in Indian Banks

- By : Parag Patel

…of holding undeclared accounts in Indian banks, according to Nicholas Connors, a supervisory revenue agent” with SB/SE. Kristen A. Parillo, IRS Will Soon Examine U.S. Taxpayers With Undeclared Indian Bank

2 recent IRS developments that will impact Indian Americans

- By : Parag Patel

…last few years, the US Internal Revenue Service (IRS) has been focusing heavily on tracking offshore accounts of its residents and citizens. Today, there are several forms to be filed…

IRS list of “dirty dozen” tax scams

- By : Parag Patel

…a special offshore voluntary disclosure initiative (OVDI) designed to bring offshore money back into the U.S. tax system and help people with undisclosed income from hidden offshore accounts get current…

New IRS IRM with Updated Streamlined Filing Compliance procedures

- By : Parag Patel

…income or foreign assets, generally, foreign bank accounts. In part, the revised procedures address concerns of taxpayers and their professional advisers that the traditional offshore voluntary disclosure programs (OVDPs) often…