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

- By : Parag Patel

…she filed a false Report of Foreign Bank and Financial Accounts (FBAR) for 2009 and a false amended tax return for 2009 that reported ownership of a foreign bank account…

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….

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…

Pennsylvania’s 2010 Tax Amnesty Program

- By : Parag Patel

…eligible for the tax amnesty program. The tax amnesty does not include Unemployment Compensation because it is administered by the PA Department of Labor and Industry. Also, the program does…

Opt Out of OVDI Program Penalties to Get a Lower Penalty

- By : Parag Patel

Under the 2011 Offshore Voluntary Disclosure Initiative (OVDI) or 2012 Offshore Voluntary Disclosure Program (OVDP), the 2012 program gives no discretion to the IRS agents to reduce penalties. If a…

IRS Form 8938 and the Offshore Voluntary Disclosure Program (OVDP)

- By : Parag Patel

program for U.S. taxpayers with offshore assets, particularly the success of the previous programs and the wealth of information gathered by the IRS which would allow it to investigate (and…

Denied access to or withdrew from the IRS Offshore Voluntary Disclosure Program (OVDP)?

- By : Parag Patel

…applied for pre-clearance into the program but were either denied access to OVDP or withdrew from the program of their own accord. Taxpayers, who have yet to resolve their non-compliance…

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…

Educational Panel Discussion: The U.S. Government’s Global Crackdown on Tax Evasion: Where It Has Been and Where It Is Going

- By : Parag Patel

…regarding some details of the US DOJ Program for Swiss Banks. She said that the information received from US DOJ Program for Swiss Banks and OVDP will lead to new…

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

HSBC Expected to Disclose Account Holders Names

- By : Parag Patel

Swiss secrecy laws (like Swiss or tax haven banks). There is a long-standing set of principles that guide the Justice Department in deciding whether to bring a criminal complaint versus…

Foreign Account Tax Compliance Act (FATCA) online registration program is launched

- By : Parag Patel

banks, investment funds and insurance companies to report to the IRS Americans’ offshore accounts worth more than $50,000. It was enacted after a Swiss banking scandal showed U.S. taxpayers hid…

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…

Reasons to Opt Out of the 2011 OVDI Program

- By : Parag Patel

Top 4 Reasons to Opt Out of the 2011 OVDI Program 1. The IRS Taxpayer Advocate’s Report: Although the IRS has not closed very many opt-out cases, the average civil…

IRS Announces New Clarifying FAQs for Streamlined Offshore Compliance Program

- By : Parag Patel

The IRS updated its streamlined offshore compliance program to provide procedures taxpayers residing both inside and outside the United States should use to participate in the program. The streamlined offshore…

What Is The Difference Between the SDOP and the Current OVDP program?: Willfulness

- By : Parag Patel

What Is The Difference Between the SDOP and the Current OVDP program? The Streamlined Offshore Procedures (SDOP and SFOP) liberalizes the old restrictions and rewards taxpayers that disclose their offshore…

Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP) opt-out results and updates

- By : Parag Patel

Many of our clients are carefully considering OVDI opt-outs. The opt out option became first available during the 2011 OVDI program, and continues with the current OVDP program. The 2012…

American Citizens Abroad (ACA) writes letter to IRS Commissioner regarding unfair offshore asset treatment

- By : Parag Patel

…fact, the IRS steered many people into the program who made honest mistakes.” Many participants in the OVDP program have been Americans living overseas who had no idea they had…

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

- By : Parag Patel

…Foreign Account Tax Compliance Act (FATCA), the IRS announced a new amnesty program to take the place of the 2009 program; the official title was the 2011 Offshore Voluntary Disclosure…

IRS announces two new intriguing targeted enforcement campaigns

- By : Parag Patel

…Offshore Private Banking enforcement campaign The new Offshore Private Banking enforcement campaign was also recently announced by the IRS. US persons are subject to tax on worldwide income, including income…

IRS Official Provides Insights for the new IRS Streamlined Compliance Procedures

- By : Parag Patel

…with others that occurred regarding bank secrecy, taxation, and/or disclosure of any foreign accounts; failure to seek independent legal advice about how to properly handle the foreign bank account and…

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….

IRS’s four offshore programs have netted 39,000 taxpayers and over $5.5 billion

- By : Parag Patel

…IRS’s four offshore programs have resulted in more than 39,000 disclosures by taxpayers, producing over $5.5 billion in revenue. The offshore disclosure programs attract taxpayers by offering a reduced risk…

IRS Targets Non-Resident Indians with HSBC Accounts

- By : Parag Patel

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…

Reasonable Cause Defense Denied: FBAR Penalties Assessed by Court

- By : Parag Patel

…form of CDs that were held in India. In or around 2002, Agrawal invested in CDs at the State Bank of India (the largest bank in India). Some of these…

New Comments on the IRS Voluntary Disclosure Program

- By : Parag Patel

We are members of the American Bar Association Section of Taxation, which on September 28, 2021 submitted comments to the IRS on the IRS Voluntary Disclosure Program (“VDP”), the Streamlined Domestic Offshore Program

National Taxpayer Advocate Identifies OVDP Program as a Serious Problem

- By : Parag Patel

…the “one-size-fits-all” approach of the IRS Offshore Voluntary Disclosure Program (OVDP), and identified the OVDP program as a most serious problem requiring resolution. The Report states that the IRS discouraged…

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

- By : Parag Patel

…use the Streamlined Domestic Offshore Procedures (SDOP)) taxpayers alike. The SFOP significantly expands the old Streamlined Program for Non US-residents, which was narrowly only for non-filers with less than $1500…

Benefits and consequences of entering or failing to enter the Offshore Voluntary Disclosure Initiative program

- By : Parag Patel

programs. As a result, we have succinctly summarized some of the benefits of entering and consequences of failing to enter the Offshore Voluntary Disclosure Initiative program. Consequences Of Not Entering…

New offshore voluntary disclosure program (OVDP) changes expected to be favorable to taxpayers

- By : Parag Patel

…willingly remedy past mistakes.” We hope that taxpayers (including our clients) currently in the program under 2011 OVDI or 2012 OVDP will be able to take advantage of the program