Search Results for: swiss program bank
What HSBC India Accountholders Can Expect From the IRS
…preliminarily cleared (the first stage of the OVDI process) to enter OVDI will not be removed from the OVDI program (even prior to the final filing of the taxpayer’s OVDI…
For Tax Professionals: A Guide to the IRS’s Voluntary Disclosure Practice
…potential criminal and civil penalties involved, participation in the IRS’s Voluntary Disclosure Practice should be carefully considered by any non-compliant taxpayer. Before advising such a client regarding this program, any…
New Favorable Court Decision: One penalty (not multiple) applies for late FBAR filing
…which is a program that allowed taxpayers to voluntarily report undisclosed offshore financial accounts in exchange for predictable and uniform penalties. After the IRS accepted the taxpayer into the program,…
New IRS guidance Announced for IRS Streamlined Offshore Procedures.
…programs require U.S. taxpayers to certify that their prior non-compliant conduct was non-willful. The IRS earlier this month announced new guidance under the Streamlined programs. The new guidance announces three…
U.S. Taxpayers at New Risk of Audit from OVDP Declines and Withdrawals Campaign
…one of the programs taxpayers may use to become compliant if they previously had failed to report offshore income on their tax returns and file Reports of Foreign Bank and…
Cost of Compliance Rises under OVDP
…a list of banks and institutions that trigger the higher 50-percent penalty under the OVDP. As we have previously noted, the IRS has a series of voluntary disclosure programs and…
2011 Offshore Voluntary Disclosure Initiative (OVDI)
…entities such as corporations, trusts and partnerships. As with other programs in the past, the OVDI eliminates the risk of criminal prosecution for taxpayers that are accepted into the program,…
What if You Missed the OVDI Deadline?
…expiration of the IRS’s OVDI program. While the civil penalties may be different (could be higher or lower than the penalties that were imposed under the OVDI program based on…
Solution: Streamlined Domestic Offshore Procedures
…Once they discover their tax and reporting obligation, there are a number of programs through which they can become compliant. One option, if the taxpayers meet the requirements, is to…
HSBC Payment of Largest Penalty and FATCA Encourages Taxpayers to Disclose
…upon HSBC’s conduct in violation of the Bank Secrecy Act and other U.S. sanctions. This penalty assessment does not merely flow from a single act but rather a systematic failure…
Foreign pension accounts reporting on the FBAR
…three pillars. The first pillar is often a social security-type program – a welfare program providing defined benefits for old age and disability. This type of plan is not FBAR-reportable….
Vatican Signs FATCA Agreement
…under the umbrella of the Offshore Voluntary Disclosure Program (OVDP). Last year, the IRS announced its new streamline program for non-willful taxpayers with lower penalties to make it more appealing…
New IRS Form 8938 Statement of Foreign Financial Assets is causing significant confusion
…account. Current law phases in reporting by foreign banks of US owned accounts. In 2014 and 2015, banks need only to disclose the owner’s identifying information, account number and balance….
FBAR compared to Form 8938: Differences, Which to File, When to File, etc.
…submit Form 8938 and/or FinCEN Form 114 (Report of Foreign Bank and Financial Accounts) to the IRS. These forms are used by the IRS to keep track of your foreign…
HSBC customer Josephine Bhasin Criminal Sentencing Very Light
…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…
FBAR Reporting Season is here
…a bank account, brokerage account, mutual fund, trust, or other type of foreign financial account which exceeds certain thresholds, the Bank Secrecy Act may require you to report the account…
The Unknown Tax: New Jersey Inheritance Tax
…these cases, Form L-8 can be used to release bank accounts, stocks, bonds, and brokerage accounts. Form L-8 is a Self-Executing Waiver and is filed with the bank, financial institution,…
President Trump Revamps the IRS through his 2019 Taxpayer First Act
…taxes but does not know his or her identity (e.g., holders of offshore bank accounts), it can issue a summons (a “John Doe summons”) to a bank or other third…
IRS Official Announces New Focus on Offshore Assets in Indian Banks
…of holding undeclared accounts in Indian banks, according to Nicholas Connors, a supervisory revenue agent” with SB/SE. Kristen A. Parillo, IRS Will Soon Examine U.S. Taxpayers With Undeclared Indian Bank…
To Opt Out or Not Opt Out: That is the Question
When is it appropriate to make a quiet disclosure vs. making a disclosure through the Offshore Voluntary Disclosure Program? This question is not necessarily easy to answer. IRS agents handling…
New EZPASS OVDP Without Any Penalties for Non-Resident U.S. Taxpayers
…which in some cases may include more than three years, in a manner similar to opting out of the Offshore Voluntary Disclosure Program”. Opting may not be a bad situation….
IRS collects over $5 billion in its its offshore voluntary disclosure programs
The Internal Revenue Service (IRS) has announced that its offshore voluntary disclosure programs (OVDPs) have collected more than $5 billion, and that it has tightened the eligibility requirements of the…
Recent Court Decision Shows Risks of IRS Streamlined Filing Compliance Procedures
…and supporting documents. Tax counsel must carefully evaluate and professionally assess a taxpayer’s eligibility for the Streamlined Program, then draft a narrative statement that complies with the Streamlined Program requirements….
New Post-OVDP IRS Voluntary Disclosure Procedures Announced
The Internal Revenue Service released new updated procedures for voluntary disclosures since the old Offshore Voluntary Disclosure Program (OVDP) closed on September 28, 2018. Last week, IRS deputy commissioner Kirsten…
Supplemental Needs Trusts
…or mentally disabled persons and still allow such persons to be qualified for and receive governmental health care benefits, especially long-term nursing care benefits, under the Medicaid welfare program. Supplemental…
Latest Medicaid Information for New Jersey for 2011
…an “income cap” state? Yes and no. The regular Medicaid program has an income cap. The more restrictive medically needy program is capped at the Medicaid reimbursement rate for the…
News from the 2014 Criminal Fraud and Tax Controversy Conference
…were in attendance. Below are some interesting observations: On the new IRS Streamlined program (including the SDOP and SFOP programs), David Horton LB&I director for international compliance (who is in…
Happy Birthday Streamlined Filing Compliance Procedure!
…program. Taxpayers who have failed to comply with their US tax filing and information reporting obligations should be aware of and seek appropriate advice regarding which disclosure program to pursue….
Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Domestic Offshore Procedures (SDOP)
…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 versus…
Hiding Money or Income Offshore Among the “Dirty Dozen” List of Tax Scams for the 2015 Filing Season
…2012, the IRS reopened the Offshore Voluntary Disclosure Program (OVDP) following continued strong interest from taxpayers and tax practitioners after the closure of the 2011 and 2009 programs. This program…