Cayman Islands Advisors Arrest Suggest U.S. Government Receiving More Information About Offshore Accounts

- By : Parag Patel

…result of this probe. Taxpayers are ineligible to participate in the IRS’s offshore voluntary disclosure program (OVDP) for undeclared offshore accounts if U.S. authorities already have their names. The program

HSBC India Customer New Indictment Uncovers More HSBC Details

- By : Parag Patel

…Credit Suisse Group AG, Switzerland’s two biggest banks, and London-based HSBC, Europe’s biggest bank. The superseding indictment signals a ramping up of pressure on HSBC and could lead to charges…

New Much-Needed Guidance for Non-Willful FBAR violations

- By : Parag Patel

…Report of Foreign Bank and Financial Accounts (FBAR), and IRM 4.26.17,Report of Foreign Bank and Financial Accounts (FBAR) Procedures, no later than one year from the date of issuance.  …

New IRS Guidelines for Willful FBAR violations

- By : Parag Patel

Last week, the Internal Revenue Service released interim guidance (SBSE-04-0515-0025) on foreign bank account report (FBAR) penalties to improve the administration of the FBAR compliance program. The guidance contains amendments…

New Extended Deadline for OVDI

- By : Parag Patel

…Account (FBAR), in prior years to report a foreign bank account or signature authority over a foreign bank account owned by an employer. Similar is permitted for delinquent Form 5471,…

Method to Cure Delinquent or Incomplete Foreign Information Returns Without Penalties

- By : Parag Patel

…years to report my personal foreign bank account or to report the fact that I have signature authority over bank accounts owned by my employer. May I come forward under…

Checklist of tax forms for taxpayers with foreign assets

- By : Parag Patel

…the trust. Form TD F 90-22.1: Report of Foreign Bank and Financial Accounts (FBAR) — If you own or have authority over a foreign financial account, including a bank account,…

IRS Announces New Rules for FBAR Penalties

- By : Parag Patel

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…

Difference between Form 8938 and FBAR Requirements

- By : Parag Patel

…8938, which is due with the tax return itself, and the Foreign Bank Account report (FBAR), which is due by June 30 to the U.S. Treasury Department. Last week the…

Is HSBC the next UBS nightmare?

- By : Parag Patel

Last year, UBS Bank avoided prosecution by paying $780 million and admitting it helped Americans evade taxes. Last August, US Justice Department issued a summons against UBS that had sought…

Beware: IRS Reminds Taxpayers of FBAR Deadline

- By : Parag Patel

Last week, the Internal Revenue Service reminded all taxpayers with a filing requirement for a foreign bank account report to report their foreign assets by the June 30 deadline. The…

Corporate Transparency Act (CTA) Reporting Company Analysis and FAQs

- By : Parag Patel

…any such Indian tribe, State, or political subdivision. Bank. Any bank, as defined in (A) Section 3 of the Federal Deposit Insurance Act; (B) Section 2(a) of the Investment Company…

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…

IRS Issues Reminders for FBARs and other International Requirements

- By : Parag Patel

…the same time, the agency advised anyone with a foreign bank or financial account that a new deadline now applies to reports for these accounts, often referred to as FBARs….

Pandora’s Box Has Opened: Pandora Papers

- By : Parag Patel

…as those unearthed in the Pandora Papers: bank accounts, private jets, yachts, mansions and works of art by Picasso or Banksy. As government tax officials start reading the Pandora Papers,…

Foreign Retirement Plans: New IRS Exemption from Required Information Reporting on Forms 3520 and 3520-A

- By : Parag Patel

…Provident Fund (MPF): Hong Kong MPF funds may qualify for relief. Swiss Pillar 3: Swiss Pillar 3 plans may qualify for relief. UK Self-Invested Personal Pension (SIPP) plan: For United…

In Addition to HSBC, Credit Suisse Also Being Investigated for Offshore Activities

- By : Parag Patel

…points out that it has obligations under Swiss law, and those are not small. Credit Suisse says it will continue to cooperate with the U.S. authorities, subject to those rules….

Government Report Advises IRS to Increase Awareness of Offshore Account Rules to Help Immigrants

- By : Parag Patel

…having offshore accounts, and more than half of them had accounts at Swiss bank UBS. Tax evasion by individuals with unreported offshore financial accounts was estimated by one IRS commissioner…

India Expected to Sign FATCA Agreement Tomorrow

- By : Parag Patel

…holders”. While the IRS has recently targeted Swiss, Israeli and Indian banks, India continues to be a focal point for the U.S. government. While new criminal prosecutions start and continue,…

Beware: India to sign FATCA agreement with US for sharing of information

- By : Parag Patel

…on behalf of U.S. individual account holders”. While the IRS has recently targeted Swiss, Israeli and Indian banks, India continues to be a focal point for the U.S. government. While…

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…

OVDP Ineligibility Possibility Increases

- By : Parag Patel

…was under investigation earlier this year. We believe that many other banks are also under investigation. For accountholders on the HSBC list, which was provided to the IRS earlier this…

Employers Must Re-examine Employee Retention Credit (ERC) Claims

- By : Parag Patel

…improper claims. Options for Employers with Incorrect Claims ERC Voluntary Disclosure Program (Deadline was March 22, 2024; may be extended): Repay 80% of the incorrect ERC, with reduced penalties and…

IRS’ New “Dirty Dozen” list of tax scams

- By : Parag Patel

…specific criteria under law to qualify for reducing their tax bill. But unscrupulous companies oversell the program to unqualified candidates so they can collect a hefty fee from taxpayers already…

New Comments of the IRS’ New Streamlined Filing Compliance Procedures for Non-Resident Non-Filer U.S. Taxpayers

- By : Parag Patel

…offshore accounts should nonetheless apply to the program if they are low-risk account holders. – The streamlined program, introduced August 31, was meant as a way to allow low-risk, noncompliant…

New IRS internal procedure guidance for Streamline Filing Compliance Procedures

- By : Parag Patel

…receiving follow up inquires from the IRS for some of our streamlined program filers.   The streamlined program offers a good option for many taxpayers with undeclared accounts. Our firm…

IRS Revises Delinquent International Information Return Submission Procedure (DIIRSP)

- By : Parag Patel

…Disclosure Program or the Streamlined Filing Compliance Procedures to file delinquent international information returns. We have successfully filed hundreds of DIIRSP filings for clients since the DIIRSP program was started…

Happy Birthday Streamlined Filing Compliance Procedure

- By : Parag Patel

…the disclosure of foreign assets. SFCP has two sub-programs: one for US residents (Streamlined Domestic Offshore Procedures or “SDOP”) and one for non-US residents (Streamlined Foreign Offshore Procedures or “SFOP”)….

Parag Patel Esq. speaks at the National Association of Enrolled Agents

- By : Parag Patel

Parag Patel Esq. is a featured speaker at the National Association of Enrolled Agents (NAEA) Estate and Gifts Certificate Program on November 7, 2023. Mr. Patel will speak on Estate…