30-DAY LETTERS VS. 90-DAY LETTERS IN TAX AUDITS
In a tax audit situations, the IRS only has a 3 year statute of limitations to assess additional taxes. If the IRS takes too long to initiate an audit, or the audit drags on too
Reasons to Opt Out of the 2011 OVDI Program
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 FBAR penalty assessed against those opting
Opt Out of OVDI Program Penalties to Get a Lower Penalty
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 participant does not believe that
FBAR Deadline is June 28, 2013
This month we remind taxpayers of the upcoming June 30, 2013 deadline for filing Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), to report financial interests in, or signature authority over,
Finally: IRS Reminds Those with Foreign Assets of U.S. Tax Obligations
The IRS has finally decided that educating taxpayers and tax advisors of tax obligations of foreign assets and income would be helpful and encourage compliance. The recent education announcements appear to address the IRS’ alleged
HSBC Customer Avoids Jail in Tax Evasion Case
A New Jersey businessman who cooperated with prosecutors avoided prison after admitting he conspired with five HSBC Holdings bankers to hide his Indian bank accounts from U.S. tax authorities. Vaibhav Dahake, 46, was sentenced to
HSBC Bank Expects Significant Penalties from US Government for Violations
Global bank HSBC has said it may face “significant” penalties from the US authorities with regard to an ongoing probe into suspected tax evasion by the US-based clients of its Indian unit, among other cases.
Finally. Government Accountability Office makes recommendations to the IRS for tax laws education to immigrants
In latest report from a government watchdog agency called the Government Accountability Office (GAO) the GAO makes recommendations to the IRS, and the IRS pays attention. Those recommendations could put some taxpayers in trouble, but some are beneficial. Particularly
Mobility of Estate Plan Documents
Many clients ask if they must re-do their estate plan when they move to a different state. The answer is generally “no”. A Will made in New Jersey or New York or Florida is likely
IRS’s four offshore programs have netted 39,000 taxpayers and over $5.5 billion
The Internal Revenue Service has collected over $5.5 billion in revenue from taxpayers who came forward and reported on their foreign holdings under its Offshore Voluntary Disclosure Programs, but it could be missing billions more
Government Report Advises IRS to Increase Awareness of Offshore Account Rules to Help Immigrants
The Internal Revenue Service’s four amnesty programs for those who have undeclared offshore accounts have resulted in more than 39,000 disclosures by taxpayers and more than $5.5 billion in revenues as of December 2012. A
COURT AUTHORIZES SERVICE OF JOHN DOE SUMMONS SEEKING THE IDENTITIES OF U.S. TAXPAYERS WITH OFFSHORE ACCOUNTS AT CIBC FIRSTCARIBBEAN INTERNATIONAL BANK
WASHINGTON – The Justice Department announced that late yesterday a federal court in San Francisco entered an order authorizing the Internal Revenue Service (IRS) to serve a John Doe summons seeking information about U.S. taxpayers