...FBAR penalty regime. We have been aggressively pursuing OVDI opt-outs for some of our clients. In doing so we have been advocating for Normal FBAR Penalty Mitigation to apply. For...
...to declare even accounts over which they have signature, but which they do not own. This is particularly damaging to the many American women who are married to non-Americans and...
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...
...of requests for such data. Don’t fall prey to people who encourage you to claim deductions or credits you are not entitled to or willingly allow others to use your...
...opens up a new chapter in the U.S. crackdown on tax evasion. Previous cases focused on Americans with Swiss bank accounts, the most notable of which was the John Doe...
...an anonymous basis, a taxpayer may initially approach the Division anonymously to seek informal guidance on an issue and later make a formal letter ruling request providing the identity of...
...will be notified whether the disclosures have been preliminarily accepted or declined. Upon acceptance into the OVDI, taxpayers will be instructed to submit their full voluntary disclosure package, which must...
...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,...
...This is a second opportunity for those U.S. taxpayers who have not already disclosed their foreign bank accounts are encouraged to take advantage of this rare second chance to come...
...reached, a Final Determination will be issued and the taxpayer may then exercise their further appeal rights. Ensuring that the Branch has updated information for telephone and e-mail contacts for...
...than to hold the equipment used in the practice. The existing equipment is then either sold or contributed to the equipment leasing entity, which then leases it back to the...
...each tax delinquent, the department will send a written notice to the last known address on the department’s records. This notice will contain important information for the recipients to participate...
