FBAR Reporting Season is here

- By : Parag Patel

…file foreign financial account reports during the current period, please note the updated information related to reports regarding foreign financial accounts which is set forth on the IRS website: http://www.irs.gov/Businesses/Small-Businesses-&-Self-Employed/Report-of-Foreign-Bank-and-Financial-Accounts-FBAR…

The Unknown Tax: New Jersey Inheritance Tax

- By : Parag Patel

…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,…

Do You Have to Pay US Taxes on Foreign Inheritance?

- By : Parag Patel

…Reporting Foreign Bank Accounts Holding Cash – Cash held in a foreign bank account is relatively simple to report. In addition to reporting the inheritance on Form 3520, there may…

India issues FATCA Self-certifications and KYC Warnings

- By : Parag Patel

…all foreign banks report bank data to the IRS. All Indian investors (including NRIs), who hold accounts in any Indian financial institutions such as mutual funds or fixed deposits, need…

A Lesson to be Learned from US v. Schwarzbaum: Bring Back the Foreign Funds to Pay FBAR Penalties

- By : Parag Patel

…gifts were deposited into Swiss bank accounts which were controlled by Schwarzbaum. Thereafter, Schwarzbaum did not timely file his FBARs for said foreign accounts and a willful FBAR penalty case…

High Penalties for failure to file an FBAR: Not Really Enforced (yet)?

- By : Parag Patel

U.S. persons, including U.S. citizens, residents, corporations and estates, must report certain foreign financial accounts, including bank accounts, brokerage accounts and saving accounts to the U.S. Treasury department each year….

More Swiss Banks Agree to Disclose US Customers Accounts: Expect More Customer Letters to be Sent

- By : Parag Patel

…of letters are being sent to US customers with Swiss accounts held over the past 5 years. Valiant Holding, Berner Kantonalbank, and Vontobel Holding AG are the first Swiss banks…

IRS attempts to demystify its new Form 8938

- By : Parag Patel

…foreign financial institution. Examples of financial accounts include: Savings, deposit, checking, and brokerage accounts held with a bank or broker-dealer. And, to the extent held for investment and not held…

Article Discusses Termination of Offshore Voluntary Disclosure Program (OVDP) and the Streamlined Filing Compliance Procedures (SFCP)

- By : Parag Patel

…US residents (Streamlined Domestic Offshore Procedures or “SDOP”) and one for non-US residents (Streamlined Foreign Offshore Procedures or “SFOP”). Each program has its own set of tailored procedures and eligibility…

IRS Streamlines its Streamlined Offshore Procedures with More User Friendly Forms

- By : Parag Patel

…below: Form 14653–Certification by U.S. Persons Residing Outside of the United States for Streamlined Foreign Offshore Procedures Form 14654–Certification by U.S. Persons Residing in the United States for Streamlined Domestic…

All the Many FBAR Late Filing Procedures

- By : Parag Patel

…SDOP program submissions. To learn more of SDOP go to: https://patellawoffices.com/blog/planning-for-tax-minimization/new-streamlined-domestic-offshore-procedures-sdop-is-a-game-changer-2/  Streamlined Foreign Offshore Procedures or SFOP To be eligible for this program, a Taxpayer must be qualified as a…

Opting Out of the Offshore Voluntary Compliance Initiative Programs

- By : Parag Patel

As with other IRS’ 2009 and 2011 offshore voluntary compliance initiatives, the 2012 program gives no discretion to the IRS agents to reduce penalties. If a participant does not believe…

New offshore voluntary disclosure program (OVDP) changes expected to be favorable to taxpayers

- By : Parag Patel

…preparing a new offshore voluntary disclosure program (OVDP) that will be easier on “law-abiding” American residents abroad. Koskinen disclosed that, “while the 2012 OVDP and its predecessors have operated successfully,…

IRS Announces New Investigative Units

- By : Parag Patel

…scouring its data collected from Foreign Account Tax Compliance Act (“FATCA”) reporting, the Offshore Voluntary Disclosure Program (“OVDP”), and the Swiss Bank Program, and analyzing data published by whistleblowers, including…

U.S. Taxpayers at New Risk of Audit from OVDP Declines and Withdrawals Campaign

- By : Parag Patel

…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…

Instructions for New Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer U.S. Taxpayers

- By : Parag Patel

…are being implemented in recognition that some U.S. taxpayers living abroad have failed to timely file U.S. federal income tax returns or Reports of Foreign Bank and Financial Accounts (FBARs),…

More Swiss Banks Agree to Cooperate with the IRS

- By : Parag Patel

…veil on bank secrecy in the Alpine country, the world’s largest offshore finance center with more than $2 trillion in assets. Under the deal, Swiss banks have until the end…

IRS Announces New Statistics Regarding Voluntary Disclosures

- By : Parag Patel

…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….

Most Swiss banks participating in the US Department of Justice (DOJ) amnesty program seek extension to disclose

- By : Parag Patel

…Banque cantonale de Geneve Berner Kantonalbank Banque Cantonale Vaudoise Graubuendner Kantonalbank Banque cantonale du Jura Zuger Kantonalbank Luzerner Kantonalbank Valiant Linth Bank Coop Bank Walliser Kantonalbank Hypothekarbank Lenzburg Unlisted banks…

What is a “FATCA Compliance Certificate”?

- By : Parag Patel

…US authorities. FATCA requires financial institutions to carefully review the client records in order to identify foreign customers. The bank review includes careful scrutiny of bank electronic databases, bank paper…

FBARs from Wuhan

- By : Parag Patel

…return and two counts of failing to file reports of foreign bank and financial accounts (FBAR) with the Internal Revenue Service (IRS).  The indictment alleges that Lieber served as the…

US Government Continues to Pressure Swiss Banks

- By : Parag Patel

…Zurich-based Swisspartners Group. The firm acknowledged helping American clients maintain undeclared bank accounts and will pay USD4.4 million in forfeitures and restitution. Methods used by the firm included selling insurance…

Consequences of Filing False Streamlined Filings

- By : Parag Patel

The IRS Streamlined Domestic Offshore Program (“SDOP”) allows eligible U.S. Taxpayers who failed to disclose foreign financial accounts to voluntarily disclose their conduct to the IRS and pay a reduced…

Willful FBAR Penalties

- By : Parag Patel

U.S. Citizens who have a financial interest in or signature authority over foreign bank accounts that hold an aggregate amount greater than $10,000 are required to report the accounts to…

Caution: Increased FBAR Enforcement

- By : Parag Patel

…report the income from the foreign accounts.  Over the years, they did not tell their accountant about the foreign accounts because they wanted to keep the accounts secret. The IRS…

OVDP Ineligibility Possibility Increases

- By : Parag Patel

accounts having a high balance of the equivalent of $50,000 at any time between 2003 and 2011. U.S. persons having interests in foreign financial accounts should not find comfort in…

Top myths of US tax compliance for Foreign Accountholders

- By : Parag Patel

…has major penalties. However, the IRS has modified one of its amnesty programs, the Streamlined Offshore Filing Procedures, to eliminate late filing and FBAR (Foreign Bank Account Report) penalties. Under…

For the First Time IRS Issues Information on 2011 Offshore Voluntary Disclosure Initiative (OVDI) in Hindi Language

- By : Parag Patel

In an effort to reach all taxpayers, including those ensnared in the pending HSBC subpoena to disclose customer names of non-resident indian customers with offshore accounts, the IRS has published…

To Opt Out or Not Opt Out: That is the Question

- By : Parag Patel

…returns showing the income regarding the offshore accounts, and let the IRS decide whether to impose the statutory FBAR penalties. As per the IRS FAQs website, “Taxpayers who have already…

Foreign Account Penalties Are Unfair

- By : Parag Patel

Our office is advising dozens of clients (including many HSBC customers) regarding offshore accounts, all of whom may be subject to large unfair penalties. Finally it appears that someone in…