Search Results for: swiss program bank
How to Avoid Jail and Clean Up Tax Problems
…without criminal liability. The IRS has a longstanding program through which taxpayers can make voluntary disclosures of tax underreporting and tax criminal evasion. The latest voluntary disclosure program is known…
IRS Announces New Statistics Regarding Voluntary Disclosures
…The IRS warned that potential civil penalties increase substantially if U.S. taxpayers associated with participating banks wait to apply to the offshore voluntary disclosure program to resolve their tax obligations….
The New IRS Voluntary Disclosure Practice: Not a Good Deal for Noncompliant Taxpayers
…an agreement or cooperate with examiner may trigger higher penalties. I believe there has been little interest in the VDP program because the program does not offer the finality and…
Details of the Streamlined Foreign Offshore Procedures (SFOP)
…ways to address past noncompliance remain viable, including the OVDP program and Delinquent FBAR Submission Procedures and Delinquent International Information Return Submission Procedures. The analysis to enter the one program…
NJ Division of Taxation Offers Offshore Voluntary Compliance Initiative
The New Jersey Department of Treasury, Division of Taxation announced today that it will offer a Second Voluntary Compliance program to complement the Internal Revenue Service Second Special Voluntary Disclosure…
File a Protective Claim for Refund for Possible OVDP Opt Out Cases
In 2009, the IRS had introduced an Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP). In following years, the program was reintroduced and revised. When it comes to addressing offshore filing deficiencies, several…
Opting-out or Opting-in of OVDI
…of electing out of the IRS program, which sounds counterintuitive. Opting out of the program can clearly make sense for some people. Up until now there’s been much nervous talk…
The Risks of “Opting Out” of OVDI
Under the 2011 OVDI voluntary disclosure program, the penalties for failing to timely file Foreign Bank Account Reports, (FBAR’s) and the penalties for failure to file information returns (such as…
The “Quiet” or “Silent” Disclosure
Our office consults with many clients in determining whether they need to enter into the 2012 IRS Offshore Voluntary Disclosure Program. Because of the high 27.5% penalty in the 2012…
New Leak of Offshore Accountholders Highlights the Need to Clean Up
…with other countries under the Foreign Account Tax Compliance Act (FATCA) have cracked open access to bank information previously held in secret in other countries. If a foreign bank refuses…
IRS reminds those with foreign assets about U.S. tax obligations
…to them. The form is only available through the BSA E-Filing System website. Reminder: IRS to end Offshore Voluntary Disclosure Program The Offshore Voluntary Disclosure Program will close on Sept….
Should I close my foreign account?
Suppose you have a foreign bank account holding more than $10,000. You may have inherited it, used it to hide money during a dispute with your spouse or business partner,…
New FinCEN Form 114 (FBAR) Filing Rules Announced
Responding to the needs of many filers who submit Reports of Foreign Bank and Financial Accounts (FBARs) jointly with spouses, or wish to submit them via third-party preparers, the Financial…
New FBAR Deadlines and Penalty Relief available
The US Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 (the Act) has changed the filing date for the Report of Foreign Bank and Financial Accounts (FBAR),…
New Court Ruling: FBAR penalties applied per form and not per account
The FBAR rules require the filing of a FinCEN Report 114, Report of Foreign Bank and Financial Accounts (FBAR) to report for accounts of U.S. persons aggregating $10,000 or more….
New Online System for Filing Your Report of Foreign Bank and Financial Accounts (FBAR)
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…
Internal Revenue Service again issues annual reminder to US persons to report foreign accounts and foreign income
…is under the Bank Secrecy Act, while the other regime was enacted within the Internal Revenue Code. The first regime pertains to the Foreign Bank Account Report, sometimes referred to…
IRS Releases New IRS 2022 FBAR Fact Sheet
…reporting requirements as domestic institutions. Civil and criminal penalties may apply for failures to properly file their Report of Foreign Bank and Financial Account (FBAR) when required. The IRS provides these details…
The questions most frequently asked about probate in New Jersey.
…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…
Rare confluence of tax law and immigration law
…alleges that in 2012-2014 Gatta failed to disclose her interest in a Swiss bank account on annual FBARs as required by law. Gatta also allegedly evaded assessment of income taxes…
Implications of United States v. Horowitz: Reckless = Willful?
…paid tax on the account’s interest income. In the case, Peter and Susan Horowitz, U.S. citizens, opened bank accounts in three Swiss banks after moving to Saudi Arabia in 1984….
New Report: Delinquent Taxpayers Could be Identified at US Border Crossings
…now that the Swiss bank non-prosecution program participation deadline of September 15, 2014 has passed. U.S. taxpayers who have been placed on the “recalcitrant” list should expect tax audit letters…
Interesting 2023 Foreign Account Cases
…an argument by an anesthesiologist that he did not seek advice concerning the tax implications or reporting obligations on a Swiss bank account because he “didn’t see a need” and…
Medicare and Medicaid Basics
…“impoverished” under the program’s guidelines. Also, unlike Medicare, which is totally federal, Medicaid is a joint federal-state program. Each state operates its own Medicaid system, but this system must conform…
Opting Out of the OVDI Program: Argue for No Penalty and a Warning Letter
The revised IRS OVDP FAQs offer helpful guidance on the opt-out option. The newly revised FAQs illustrate the pros and cons of opting out with examples. Depending on the circumstances,…
IRS Notices for OVDI Program
When the IRS receives payment with amended tax returns for taxes, interest and penalties, the IRS may misapply the payment. This results in IRS notices. Reminiscent of the mistakes of…
National Taxpayer Advocate Criticizes IRS over handling of offshore voluntary disclosures
The 2012 National Taxpayer Advocate (NTA) Annual Report to Congress criticized current IRS practices in the Offshore Voluntary Disclosure Program (OVDP) that hinder voluntary compliance by penalizing taxpayers who are…
Upcoming live video webinar: “FBAR and U.S. Tax Reporting: Compliance Requirements for Foreign Assets”
…tools necessary to navigate the rules regarding FBAR and available programs and planning methods in reporting offshore assets and assisting clients with developing programs that provide workable solutions. After our…
New York State Bar Association Proposes OVDI Changes to IRS
Our office is a proud member of the New York State Bar Association (NYSBA) after reading their tax section’s detailed comments on the OVDI program. This is not an anti-tax…
How to Demonstrate Non-Willfulness Under The Streamlined Filing Compliance Procedures
…a warning. While the streamlined program offers a welcome option for many taxpayers with undeclared accounts, other ways to address past noncompliance remain viable, including the OVDP program and Delinquent…