Search Results for: swiss program bank
New Streamlined Domestic Offshore Procedures (SDOP) is a Game Changer
…The SDOP requires filing only three years of amended income tax returns and assesses a 5% penalty of the highest account balance. In comparison, the current OVDP program requires eight…
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…
Citizenship renunciation fee increases as American expatriates flee FATCA
…rise in renunciations triggered by the US Foreign Account Tax Compliance Act. FATCA forces foreign banks and other institutions to report their US clients’ financial doings to the Internal Revenue…
What to Expect if the IRS Audits Your Employee Retention Credit
…in revenue or a suspension of operations Information about Paycheck Protection Program (PPP) loans Wage expense information on your business income tax return Meeting with the auditor: You will likely…
OVDP New Forms Announced by IRS
The IRS has simplified the process of entering the OVDP Program by issuing the following forms: Form 14457 – Offshore Voluntary Disclosure Letter Form 14454 – Offshore Voluntary Disclosure Program…
Details of the Streamlined Domestic Offshore Procedures
…obligation, there are a number of programs through which they can become compliant. One option, if the taxpayers meet the requirements, is to file under the Streamlined Domestic Offshore Procedures…
U.S. Signs FATCA Pacts with Malta, Netherlands, Bermuda, Jersey, Guernsey and Isle of Man
…several clients with accounts in these jurisdictions. We counseled them into the OVDP program and they fortunately and successfully are all in the OVDP program, otherwise the new FATCA agreements…
Abatement of the NJ Amnesty Non-Participation Penalty is Still Possible for Some Taxpayers
…a taxpayer that gets assessed a penalty for failing to participate in the 2009 amnesty program. If the assessment is issued after June 15, 2009 (when the 2009 amnesty program…
New Jersey Division of Taxation Now Issuing Letter Rulings
…relating to the request Optionally, the ruling request can cite legal authorities relevant to the request and proivde the taxpayer’s analysis. The new letter ruling program is a welcome development…
Forms 3520, 5471 and 5472 Penalty Relief
…U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business) when they are attached to a late-filed Form 1120 or Form 1065. Campus assessment program penalties for…
IRS gives widespread penalty relief: ACTION REQUIRED
…1065. Campus assessment program penalties for Form 3520 (Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts) and Form 3520-A (Annual Information Return of Foreign…
Comments on IRS Form 3520 to Report Foreign Gifts
…Abatement program, which currently abates specific penalties for failure to pay income tax timely. Move Part IV of Form 3520 to a Separate Form The current Form 3520 has dual…
New Form 3520 Penalties
…a new program to receive delinquent Form 3520 filings and to review the reasonable cause. This program would be similar to the streamlined filing compliance procedures for reporting and paying…
IRS attempts to demystify its new Form 8938
…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…
The legal standard of “willfulness”: Opt out to avoid high penalties
…in or signatory or other authority over a financial account in a foreign country, such as a bank account, a security account, or other financial account? The answer is either…
OVDI: Requesting issuance of a FBAR warning letter instead of penalties
…Bank and Financial Accounts,” if it would be sufficient to bring the individual into compliance, an IRS official said May 17. See Matthew Dalton, IRS May Issue Warning Letters on…
IRS Announces Penalty Mitigation for Smaller US Taxpayers Living Abroad
…not force everyone through the OVDI/OVDP programs. Yesterday, the IRS today announced a plan to help U.S. citizens residing overseas, including dual citizens, catch up with tax filing obligations and…
No tax = No Passport?
…appears not apply to taxpayers who simply fail to file returns, including Reports of Foreign Bank Accounts (FBARs). However, the timing of the legislation is interesting. The privilege of foreign…
Delinquent FinCen Form 114 (FBAR) Filings
…filings have caused confusion over the various IRS programs in place for individuals who need to become compliant with FBARs. Due to the risk of audit and high penalties, we…
Top 5 tax fraud recoveries in 2022
…criminally disregarded this requirement. He earned over $66 million from his work, but used sophisticated offshore structures, trusts, and bank accounts to conceal that income, and did not file returns…
Global Enforcement of FATCA: Something to Worry About
The Foreign Account Tax Compliance Act (FATCA) is about disclosure and transparency, but in part is to catch Americans trying to stash money overseas. Controversially, FATCA orders every foreign bank…
IRS Offshore Voluntary Disclosure Programs Continue to Burden “Benign Actors” and Damage IRS Credibility
…F 90–22 .1, Report of Foreign Bank and Financial Accounts (FBAR)) . As described in prior reports, these programs apply a one-size fits-all approach designed for “bad actors” to “benign…
What Client Tax Advisors Should Do About the New Corporate Transparency Act
…profile associated with each service level is crucial. Significant Potential Risk Exposures: CPAs providing CTA assistance face substantial potential risks, including: Bank Scrutiny: Banks may request comfort letters and supporting information…
IRS FBAR Penalties Are Now Unmitigated
The Internal Revenue Service will no longer reduce the penalty for taxpayers who non willfully fail to file Reports of Foreign Bank and Financial Accounts (FBAR or FinCen 114), according…
IRS Publicizes and Celebrates OVDI Success
…initiative, there was a penalty framework that generally required individuals to pay a penalty of 25% of the amount in the foreign bank accounts in the year with the highest…
FATCAts
…compliance procedures apply to ‘private banking’ relationships, requiring private bank managers to conduct a ‘diligent review’ of the client’s files and presuming a greater familiarity with the client’s potential US…
Estate Planning in the Electronic Age
…wishes. If you pass away unexpectedly, your family may be precluded altogether from accessing important electronic records such as emails and bank accounts. Accordingly, you need to establish a way…
New IRS procedures for Streamlined Filing Compliance Procedures for 2017 transition tax filers
…or other authority over various foreign bank accounts, including the bank accounts of Foreign Co. B, on FBARs. Her failure to file income tax returns and FBARs was non-willful. On…
Unfiled FBAR Penalties Survive Death
…in numerous foreign bank accounts that had an aggregate balance of more than $10,000. The Government asserted that the failures to file were non-willful, but assessed FBAR Penalties of $740,848…
Beware of U.S. tax consequences to a foreign trust with a U.S. beneficiary
…and an interest charge. Report of Foreign Bank and Financial Accounts (“FBAR”) Filings: FBAR filings on Form TD-F 90-22.1 are generally required to be made by U.S. persons who have…