Search Results for: penalties
Another U.S. taxpayer with an offshore HSBC bank account pleads guilty
…law office, which represents many taxpayers throughout the U.S. and around the world with undisclosed offshore accounts, believes that the recent indictments and large penalties should encourage more U.S. taxpayers…
Recent Court Decision Shows Risks of IRS Streamlined Filing Compliance Procedures
…estate (Taxpayer) attempted to become compliant through the IRS’s Streamlined Domestic Offshore Procedures (“SDOP”). The IRS flagged the submission and assessed the maximum willful FBAR penalties against the Taxpayer because…
Cost of Compliance Rises under OVDP
…other options to come into compliance with U.S. filings, some of which can give rise to zero penalties. The primary program imposes a penalty at 27.5% – with the higher…
Foreign Gifts and the Uncommon Form 3520: A Trap for the Unwary
We have had several clients recently subject to Form 3520 penalties, so we thought we would remind everyone of the need to timely file these forms when receiving a foreign…
Fifth HSBC India Customer indicted for tax evasion this year
…expiration, for protection against civil (and criminal) penalties. In light of recent indictments, quiet or no disclosures are not viable options for such individuals. Our law office, which represents many…
What is the U.S. tax on Inheritances from a Non-U.S. Person to U.S. Person?
…domiciled). More importantly, ownership of foreign financial assets creates other U.S. tax reporting issues that must be properly handled or there may be a risk of significant IRS penalties and…
New IRS Voluntary Disclosure Program lets employers who received questionable Employee Retention Credits pay them back
…tax season. I would expect and hope that the program gets extended to accommodate advisors and their clients. Program participants will not be charged any interest or penalties if they…
IRS Announces “Good Faith” 90 Day Extension of Voluntary Disclosure Deadline
…of time to assess tax (including tax penalties) and to assess penalties for failure to file Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR). Requests for…
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…
New offshore voluntary disclosure program (OVDP) changes expected to be favorable to taxpayers
…the type of penalties that are appropriate for US-resident taxpayers who were willfully hiding their investments overseas.” “We are also aware that there may be US-resident taxpayers with unreported offshore…
How to Avoid Jail and Clean Up Tax Problems
…penalties and possible jail time for criminal tax evasion. Few tax professionals are aware of an Internal Revenue Service program that can help taxpayers clean up past troublesome tax issues…
What Do Tax Lawyers Do?
…and penalties. A tax lawyer can help you file delinquent returns. Installment Agreements: If you can’t pay your entire tax balance in a lump sum, an installment agreement could be…
Eleven foreign financial institutions to share their US customer account information
…penalties grows greater as the IRS and Department of Justice complete more bank-investigations and as foreign banks continue to co-operate with US government officials. Offshore Voluntary Disclosure Program (OVDP) On…
New offshore account disclosure law
…continues. These provisions apply for tax years beginning after the new law’s enactment date. Penalties for underpayments attributable to undisclosed foreign financial assets. For tax years beginning after the new…
FATCA Enforcement Softens
…signed in March 2010, requires foreign banks and other financial institutions to report U.S. account holders who are evading federal taxes, or else risk steep penalties. Foreign financial institutions with…
FATCA Noncompliant Accounts may be Frozen or Blocked
…penalties would apply. As a result, we recommend to our clients that US tax reporting be cleaned up through a variety of possible IRS approved solutions prior to responding to…
Do You Have to Pay US Taxes on Foreign Inheritance?
…substantial penalties. Reporting a foreign inheritance is not a simple process and requires guidance from an experienced advisor. The following are the most common forms that must be filed when…
Foreign Account Tax Compliance Act (FATCA): More Information Sharing Agreements Expected
…the Internal Revenue Service, potentially in breach of their home countries’ privacy laws. Those that did not comply faced, among other penalties, a 30% withholding tax on payments received from…
New IRS Enforcement Letters Warn of Cryptocurrency Non-Compliance
…and penalties,” said IRS Commissioner Chuck Rettig. “The IRS is expanding our efforts involving virtual currency, including increased use of data analytics. We are focused on enforcing the law and…
HSBC officially provides information on clients having accounts in India to the US Department of Justice and IRS
…in effect today, for protection against civil (and criminal) penalties. In light of recent criminal indictments, quiet or no disclosures are not viable options for such individuals. Our law office,…
New IRS Relief for Taxpayers Experiencing COVID-related Difficulties
…below relief: · The IRS is highlighting reasonable cause assistance available through IRS procedures for failure to file, failure to pay and failure to deposit penalties. First time abatement (FTA)…
50% Penalty for Taxpayers Who Hold Accounts at a Bank Under Investigation
…taxpayers. The modifications greatly eased penalties for people who were unaware of tax and disclosure requirements. At the same time, the IRS sharply increased the penalty for people in its…
BE-10 Report: A New Overlooked International Reporting Form
…a BE-10 report. Failure to file can result in civil and criminal penalties. Civil penalties can range from fines of $2,500 to $25,000, in addition to injunctive relief requiring compliance….
The IRS Large Business and International division (LB&I) has announced a new Offshore Private Banking enforcement campaign
…activities, otherwise, they are subject to penalties and possible criminal prosecution. Via FATCA and subpoenaed bank records, the IRS is in possession of records that identify taxpayers with transactions or…
Vatican Signs FATCA Agreement
…Significant penalties apply (and possibly criminal prosecution) for failure to file required forms. Note that FATCA does not eliminate the requirement to file the FBAR. This filing requirement applies to…
Taxpayer’s Beware: Proving Non-Willful Conduct in the new IRS Streamlined Filing Compliance Procedures
…the IRS’s Offshore Voluntary Disclosure Program—for those who intentionally hid money abroad—must pay a much higher penalty: 27.5% of the account’s peak balance. Interest, other penalties and advisers’ fees can…
How to Avoid Criminal Prosecution Through Voluntary Disclosure
…seek protection from potential criminal prosecution. Through this program, a Taxpayer can limit their offshore non-compliance and thus limit their penalties to six years. The first step in Voluntary Disclosure…
New FBAR FIling Deadline Law Signed
…15th, if this is the first time the FBAR was due. High penalties apply for failure to file FBARs. However, the IRS already has discretion to waive FBAR filing penalties….
Another HSBC Customer Likely Going to Jail
…criminal) penalties. In light of recent cases, quiet or no disclosures are not viable options for such individuals. Our law office, which represents many taxpayers throughout the U.S. and around…
Caution: Foreign Businesses Require Additional Reporting
…if no tax is due, failure to file a Form 5471 can result in large penalties. CFC income reporting requirements (most importantly, the so-called “subpart F income” and “passive foreign…