Search Results for: swiss program bank
Correcting Common FBAR Errors
…taxpayer is eligible to participate in the streamlined program if his or her failure to file a U.S. tax return and/or FBAR was not willful. The streamlined program requires a…
A solution in a tough tax season: the IRS Streamlined Offshore Procedures
…the OVDP program and Delinquent FBAR Submission Procedures and Delinquent International Information Return Submission Procedures. The analysis to enter the one program versus other alternative options is complex and requires…
Taxpayer’s Beware: Proving Non-Willful Conduct in the new IRS Streamlined Filing Compliance Procedures
…that the IRS will carefully monitor taxpayer filings with large accounts making fraudulent claims in the streamlined program and punish them severely to send a warning. While the streamlined program…
Estate Planning When a Spouse is Confronting Health Issues (Estate Planning for the Healthy Spouse)
…by the Medicaid estate recovery program. N.J.S.A. 30:4D-7.2 et seq.; 42 U.S.C. §1396p(b)(1)(B). Under the estate recovery program, the State of New Jersey is entitled to recover payments made on…
Beware of FATCA Letters
…IRS should ask the bank to extend the time limit, requesting you need between 30 and 60 days to sort the matter out. Most banks will consider this reasonable. You…
New Court Case Limits the Reasonable cause exception to FBAR penalties
…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…
IRS Announces New international campaigns
…Compliance: Form 1120F Chapter 3 and Chapter 4 Withholding Swiss Bank Program Foreign Earned Income Exclusion Verification of Form 1042-S Claimed on Form 1040NR Cross Border Activities: Corporate Direct (Section…
Offshore Compliance Programs Generate $8 Billion; IRS Urges People to Take Advantage of Voluntary Disclosure Programs
…to FATCA and reporting through IGAs, the Department of Justice’s Swiss Bank Programcontinues to reach non-prosecution agreements with Swiss financial institutions that facilitated past non-compliance. As part of these agreements,…
Significant FBAR Penalties Upheld by Court
…the IRS on her tax return and on Foreign Bank Account Report (FBAR) forms. In 2009, when the IRS introduced its Offshore Voluntary Disclosure Program (OVDP), she joined the program…
An Ill-advised IRS Streamlined Filing Compliance Procedure Filing
…legal advice regarding which disclosure program to pursue. Mr. Gyetvay’s SFCP filing was too large and complex and had willful factors. He should not have filed in the Streamline program….
Foreign Account Penalties Are Unfair
…that first voluntary disclosure program expired, the IRS “clarified” that it would no longer consider whether taxpayers in the 2009 amnesty program would pay less than under existing statutes on…
Employee or Contractor?: The IRS’s New Voluntary Classification Settlement Program (VCSP)
…OVDI for foreign accounts and assets. Through these “voluntary” programs, the IRS has collected billions and is getting many taxpayers back into the IRS system in a major way. The…
Parag Patel Esq. was a featured speaker at the National Association of Enrolled Agents (NAEA) International Tax Certificate Program
Parag Patel Esq. was a featured speaker at the National Association of Enrolled Agents (NAEA) International Tax Certificate Program event from December 12-16, 2022. The five-day educational event focused on…
IRS announces new Streamlined Filing Compliance Procedures
…one or the other: either enter the 2014 OVDP or enter the 2014 Streamlined Programs. If rejected from the 2014 Streamlined Programs, taxpayers may not later enter the 2014 OVDP…
Major changes to IRS offshore voluntary compliance programs
…certification program, referred to as the IRS Streamlined filing compliance procedures (SDOP and SFOP); Under this program, taxpayers residing in the United States whose failure to report foreign financial assets…
Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Foreign Offshore Procedures (SFOP)
…the OVDP program and Delinquent FBAR Submission Procedures and Delinquent International Information Return Submission Procedures. The analysis to enter the one program versus other alternative options is complex and requires…
Analysis: IRS New Disclosure Program
…criminal prosecution can continue to use these programs or the amended return process to correct past mistakes. These programs remain very important tools for our clients to seek tax compliance….
Time Running Out for HSBC India accountholders sought by IRS
…USA, which would then transfer the funds to HSBC India. According to the declaration, in addition to offering “standard” banking services at HSBC India through its NRI Program, HSBC offered…
2 recent IRS developments that will impact Indian Americans
…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…
HSBC officially provides information on clients having accounts in India to the US Department of Justice and IRS
…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…
New FATCA Enforcement Expected
…common bank procedure is a result of the Foreign Account Tax Compliance Act, which requires foreign banks and other financial institutions, among other things, to gather and report information to…
Foreign HSBC Bank Customer Avoids Jail: Given Three Years’ Probation
A Wisconsin neurosurgeon convicted of tax charges related to a HSBC bank accounts owned abroad that held $8.76 million was spared prison and ordered to serve three years’ probation, according…
Taxpayers’ Evidence of Non-Willfulness or Willfulness Factors
…— Did the taxpayer receive regular statements from the bank? If not, did a relative or friend receive statements or did the bank have instructions not to send any statements…
The Misunderstood Extension of time to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR)
The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced an automatic six-month extension for taxpayers required to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR). Taxpayers…
A Lesson to be Learned from US v. Schwarzbaum: Bring Back the Foreign Funds to Pay FBAR Penalties
…U.S. citizen in 2000 and from 2001-2009 he received substantial monetary gifts from his Swiss father (unlike many of our clients with Swiss accounts, he was actually from Switzerland. These…
IRS Announces New Investigative Units
…scouring its data collected from Foreign Account Tax Compliance Act (“FATCA”) reporting, the Offshore Voluntary Disclosure Program (“OVDP”), and the Swiss Bank Program, and analyzing data published by whistleblowers, including…
IRS offers tax opportunity to Americans living abroad
…the IRS on suspected offshore tax evasion by wealthy Americans through Swiss banks. It also follows complaints by tax lawyers that many U.S. expatriates have been unaware of the new…
NY Art Consultant Indicted for Filing False Tax Returns and Failing to File FBARs
…fact, it was more than four times that amount. Thereafter, in 2006, Doyle opened a Swiss bank account for the purpose of depositing the inheritance from her father. The new…
IRS Announces new OVDP Declines-Withdrawals Campaign
…the IRS Offshore Voluntary Disclosure Program. Entitled, “OVDP Declines-Withdrawals Campaign,” this area of focus involves taxpayers who have applied for the offshore voluntary disclosure program through the pre-clearance process, but…
New IRS Voluntary Disclosure in 7 Steps
…resolution is reached through the new voluntary disclosure program. Overall, the change from 8 years of disclosures in OVDP to 6 years for disclosures in this new program is…