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

- By : Parag Patel

…by IRS examiners under the 2009 offshore voluntary disclosure program (OVDP). Commissioner Shulman had until the end of January 2012 to answer Olson’s Directive, but has chosen not to. ACA’s…

New offshore account disclosure law

- By : Parag Patel

…of measures to reduce offshore noncompliance by giving IRS new administrative tools to detect, deter and discourage offshore tax abuses. Here is a brief overview of the new offshore anti-abuse…

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

- By : Parag Patel

…reporting foreign bank accounts will have great difficulty with Form 8938. Since Form 8938 required to be annually filed together with the tax return, the failure to file (or being…

Foreign HSBC Bank Customer Avoids Jail: Given Three Years’ Probation

- By : Parag Patel

…crackdown on offshore tax evasion since 2008, the U.S. Justice Department has charged dozens of U.S. taxpayers as well as more than two dozen offshore bankers, lawyers and advisers. Ahuja…

Opting-out of the Offshore Voluntary Disclosure Initiative: FBAR Penalty Mitigation Guidelines

- By : Parag Patel

…Level I – Determine Aggregate Balances If the maximum aggregate balance for all accounts to which the violations relate did not exceed $50,000, Level I applies to all accounts ….

Frequent Scenarios in Offshore Voluntary Disclosures

- By : Parag Patel

…in foreign accounts, then the accounts are reporting laws and income from the accounts is includable in the U.S. person’s tax returns. If the funds were acquired by gift or…

IRS Announces Key Milestone in FATCA Implementation; U.S. Begins Reciprocal Automatic Exchange of Tax Information under Intergovernmental Agreements

- By : Parag Patel

…facilities, and improves detection of those who may attempt to evade reporting the existence of offshore accounts and the income attributable to those accounts. The IRS will only engage in…

No tax = No Passport?

- By : Parag Patel

…some offshore banks are beginning to advise U.S. account holders of their obligations to report the accounts by filing FBARs and report income earned on the foreign accounts for income…

Beware: India to sign FATCA agreement with US for sharing of information

- By : Parag Patel

…U.S. Internal Revenue Service (IRS). The agreement would provide the Internal Revenue Service (IRS), access to details of all offshore accounts and assets beyond a threshold limit held by Americans…

Vatican Signs FATCA Agreement

- By : Parag Patel

…foreign banks and other offshore accounts by US taxpayers. These locations are often touted as “safe havens” from US taxing authorities. The law went into effect on July 1, 2014,…

Checklist of tax forms for taxpayers with foreign assets

- By : Parag Patel

…the trust. Form TD F 90-22.1: Report of Foreign Bank and Financial Accounts (FBAR) — If you own or have authority over a foreign financial account, including a bank account,…

U.S. Signs FATCA Pacts with Malta, Netherlands, Bermuda, Jersey, Guernsey and Isle of Man

- By : Parag Patel

…required by FATCA about consenting U.S. accounts directly to the IRS. This requirement is supplemented by government-to-government exchange of information regarding certain pre-existing non-consenting accounts on request. Malta, the Netherlands,…

Navigating Foreign Waters: The Complex Requirements of Foreign Accounts Compliance

- By : Parag Patel

offshore accounts, you must know benefits and pitfalls of offshore accounts. We will review the rules of foreign account disclosure, FBARS: who needs to file, which accounts must be reported,…

New IRS FBAR Practice Unit

- By : Parag Patel

…assess an FBAR civil penalty against USP.  This same six-year assessment period applies whether USP files an FBAR or not. What is a Financial Account? Financial accounts include bank accounts

Foreign pension accounts reporting on the FBAR

- By : Parag Patel

…may not be able to ascertain the current value or balance of a defined benefit plan prior to retirement, or the foreign bank and financial accounts. Are foreign pension plans…

Common Issues for US-India Tax Reporting

- By : Parag Patel

…Failure to provide self-certification of compliance would result in the noncompliant accounts being blocked and inaccessible for any transactions. All Indian investors (including NRIs), who hold accounts in any Indian…

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

- By : Parag Patel

IRS Issue Number: IR-2018-52 IRS to end offshore voluntary disclosure program; Taxpayers with undisclosed foreign assets urged to come forward now WASHINGTON – The Internal Revenue Service today announced it…

New IRS procedures for Streamlined Filing Compliance Procedures for 2017 transition tax filers

- By : Parag Patel

…or other authority over various foreign bank accounts, including the bank accounts of Foreign Co. B, on FBARs. Her failure to file income tax returns and FBARs was non-willful. On…

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…

Method to Cure Delinquent or Incomplete Foreign Information Returns Without Penalties

- By : Parag Patel

Last year, the IRS announced its third offshore voluntary disclosure initiative. Like the earlier initiatives, the 2012 OVDP is designed to encourage taxpayers with unreported offshore accounts and assets to…

The IRS’s 2022 Dirty Dozen tax scams

- By : Parag Patel

…Assets: The IRS remains focused on stopping tax avoidance by those who hide assets in offshore accounts and in accounts holding cryptocurrency or other digital assets. International tax compliance is a…

HSBC customer Josephine Bhasin Criminal Sentencing Very Light

- By : Parag Patel

…false 2008 individual income tax return that did not report her ownership of a bank account in India at the Hongkong and Shanghai Banking Corporation Limited (HSBC India). Bhasin filed…

The questions most frequently asked about probate in New Jersey.

- By : Parag Patel

…does not have the discretion or right to waive the requirement. 7) How does the surviving spouse or domestic partner access joint bank accounts or certificates of deposit? Certain bank

IRS offers tax opportunity to Americans living abroad

- By : Parag Patel

…on Tuesday. The IRS said it would allow some U.S. citizens, including dual citizens, who have not filed income tax returns or not disclosed their foreign bank accounts, to come…

US FATCA Enforcement Softens due to Coronavirus

- By : Parag Patel

The Internal Revenue Service is giving foreign banks and financial institutions more time to file their forms about U.S. taxpayers with overseas bank accounts and other holdings in compliance with…

Swiss Banks are Pressuring Customers to Disclose

- By : Parag Patel

Swiss banks are pressuring current and former U.S. account holders to disclose undeclared assets to the Internal Revenue Service. In some cases, the banks are freezing accounts unless clients can…

Rare Supreme Court Ruling Favors Taxpayers!

- By : Parag Patel

…all foreign accounts each year (Boyd, 991 F.3d 1077 (9th Cir. 2021)). FBARs (Financial Crimes Enforcement Network (FinCEN) Forms 114, Report of Foreign Bank and Financial Accounts) are required to…

Seminar: Navigating Foreign Waters: The Complex Requirements of Foreign Accounts Compliance on US tax laws

- By : Parag Patel

With the IRS aggressively targeting taxpayers with unreported offshore accounts, tax professionals must know benefits and pitfalls of offshore accounts. Our firm presented technical seminars titled Navigating Foreign Waters: The…

Comparison of Form 8938 and FBAR Requirements

- By : Parag Patel

The new Form 8938 filing requirement does not replace or otherwise affect a taxpayer’s obligation to file FinCEN Form 114 (Report of Foreign Bank and Financial Accounts). Individuals must file…

IRS Publishes Useful Chart Outlining Compliance Options for Offshore Assets

- By : Parag Patel

The IRS has recently published a useful chart outlining options available to help US taxpayers with offshore interests. The new IRS chart correctly states that it “recognizes that its focus…