Search Results for: offshore bank accounts
2011 Offshore Voluntary Disclosure Initiative Frequently Asked Questions (FAQs) and Answers
…step for a taxpayer making an offshore voluntary disclosure is the submission of the Offshore Voluntary Disclosures Letter. This letter will be reviewed by IRS Criminal Investigation (CI), and taxpayers…
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…
Benefits and consequences of entering or failing to enter the Offshore Voluntary Disclosure Initiative program
Over the past several years our law firm has counseled hundreds of non-compliant U.S. taxpayers in the exploration of their legal options with respect to the Offshore Voluntary Disclosure Initiative…
IRS announces new Streamlined Filing Compliance Procedures
…percent offshore penalty based on the highest balance year unless the taxpayer has an undisclosed account at a bank listed on the IRS posted list – then it is a…
Upcoming live video webinar: “FBAR and U.S. Tax Reporting: Compliance Requirements for Foreign Assets”
…clients in utilizing any remaining available programs and development methods to ensure reporting compliance. Clients will benefit from substantially reduced or no penalties for failure to report offshore accounts. However, counsel…
Swiss Bank Disclosure Round Up
…Banque Privee Edmond de Rothschild St. Galler Kantonalbank Banque cantonale de Geneve Berner Kantonalbank Banque Cantonale Vaudoise Graubuendner Kantonalbank Banque cantonale du Jura Zuger Kantonalbank Luzerner Kantonalbank Valiant Linth Bank…
India and US signed FATCA Agreement Today
…improvement in mutual cooperation to combat offshore tax evasion and will benefit both the countries. “I am confident working together we can detect, deter and discourage offshore tax evasion, increase…
Reasonable Cause Defense Denied: FBAR Penalties Assessed by Court
…favor of the government to collect FBAR penalties for the non-willful failure to file FBARs to timely report foreign bank accounts. Agrawal represented himself, without legal counsel in court, which…
Is HSBC the next UBS nightmare?
…States by keeping hidden bank accounts in India and the British Virgin Islands, an offshore tax haven, from about 2001 until this year. It was not clear how many client…
India Signs FATCA Model Intergovernmental Agreement to Share Account Information with the US
…(IRS), access to details of all offshore accounts and assets beyond a threshold limit held by Americans here, while a reciprocal arrangement could be offered for Indian authorities as well….
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…
Beware IRS Letter 6291
…Via FATCA and subpoenaed bank records, the IRS is in possession of records that identify taxpayers with transactions or accounts at offshore private banks. Soft letters are IRS correspondence to…
US Court finds non-willful FBAR penalty not limited to $10,000 per year
…authority over, one or more accounts in a foreign country and the aggregate value of all such accounts exceeds $10,000 at any time during the calendar year. The FBAR is…
IRS Announces New Rules for FBAR Penalties
There are two types of penalties applicable to FinCEN Form 114 (Report of Foreign Bank and Financial Accounts) (FBARs): (1) Non-Willful and (2) Willful. The penalties are theoretically assessed per…
More Tax Complexity: New Form 8938
…taxpayers with foreign accounts and assets. FATCA created Form 8938, an additional foreign account reporting requirement over and above the Report of Foreign Bank and Financial Accounts (FBAR) or Form…
IRS Reminds (again) Taxpayers to Report Foreign Income and Assets
…about the existence of foreign accounts, such as bank and securities accounts, and usually requires U.S. citizens to report the country in which each account is located. Generally, U.S. citizens,…
FBAR Reforms Recommended
…114, Report of Foreign Bank and Financial Accounts (FBAR). However, FinCEN has recently made a number of proposals (RIN 1506-AB26) to revise its regulations. The proposed regulations would conform…
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….
IRS Uses New Funding to Target US Persons with Malta Accounts
…We have heard rumors that dozens of new IRS personnel are currently being trained to examine (i.e., investigate or audit) US persons with Malta accounts. US persons with Malta accounts…
New Form Updates for Foreign Accounts
The government has made a few recent form updates regarding the filing requirements for the following forms: FinCEN Form 114 (Report of Foreign Bank and Financial Accounts) – automatic…
FATCA Noncompliant Accounts may be Frozen or Blocked
…the account, including withdrawals. Numerous newspapers have reported the possibility of block accounts starting May 1, 2017. For example, the Indian mutual fund industry has announced that noncompliant accounts would…
The InSECURITY of the SECURE Act
…affect account beneficiaries who want to quickly drain inherited accounts or account owners who empty their accounts during their retirement years. It only affects certain nonspouse beneficiaries who want to…
New Comments on the IRS Voluntary Disclosure Program
…by U.S. Person Residing Outside of the United States for Streamlined Foreign Offshore Procedures, and Form 14654, Certification by U.S. Person Residing in the United States for Streamlined Domestic Offshore…
IRS Publicizes and Celebrates OVDI Success
As expected, the United States Internal Revenue Service (IRS) has disclosed that the recently-completed offshore voluntary offshore initiative (OVDI) has pushed the total number of voluntary disclosures up to 30,000…
IRS examines jewelry, precious stones and metals businesses for compliance
…that range from cash sales to competitors to bank statements. In addition to all of the requested documentation, the IRS Bank Secrecy Act fraud specialist is also requiring in-person interviews….
Taxpayer’s Beware: Proving Non-Willful Conduct in the new IRS Streamlined Filing Compliance Procedures
…announced significant changes to its limited-amnesty programs for U.S. taxpayers holding undeclared offshore accounts abroad. These offshore-account holders now can opt for a new “streamlined procedure.” Participants must file three…
What if You Missed the OVDI Deadline?
…“a race to the government” – whoever gets there first wins. Therefore, taxpayers who have unreported offshore accounts should give serious consideration to making a voluntary disclosure, even after the…
New Warnings in the IRS’ Streamlined Filing Compliance Procedures
…significantly expanded by the IRS in June 2014 in order to provide a meaningful way for non-willful taxpayers to remedy past non-compliance with respect to non-U.S. bank accounts and income…
New FATCA Enforcement Expected
…FATCA requires foreign financial institutions (FFIs), i.e., foreign banks, to report to the Internal Revenue Service (“IRS”) information about financial accounts held by U.S. taxpayers, or by foreign entities in…
The Dreaded IRS Letter 6185: “We received information that you have a foreign account”
…in possession of records that identify taxpayers with transactions or accounts at offshore private banks. Soft letters are IRS correspondence to targeted taxpayers identifying tax noncompliance and passively seeking compliance….