Last year, the IRS announced its third offshore voluntary disclosure initiative. Like the earlier initiatives, the 2012 OVDP is designed to encourage taxpayers with unreported offshore accounts and assets to...
As of yesterday, three Swiss banks have agreed to participate in a U.S. disclosure program aimed at lenders suspected of aiding tax evasion by Americans. Many more expected and thousands...
...the tax year or $75,000 at any time during the tax year (higher threshold amounts apply to married individuals filing jointly and individuals living abroad) $10,000 at any time during...
...regarding the administrative review of FBAR penalties by the IRS Office of Appeals. See http://www.irs.gov/irm/part8/irm_08-011-006.html The IRM is essentially the operational manual providing guidance and procedures for the various functions...
Reporting on a California State Bar Tax Section Meeting, Tax Notes reports that the IRS will soon (as early as the week of 11/11/13) ) “begin examining U.S. taxpayers suspected...
Over the past few years, the Tax Division of the United States Department of Justice has been aggressively investigating tax evasion by U.S. taxpayers via offshore bank accounts in countries...
...procedures Delinquent FBARs The IRS on July 24, 2013 updated its Frequently Asked Questions (FAQs) for its Offshore Voluntary Disclosure Program (OVDP). Under the OVDP’s 2012 announcement, the IRS provided...
...extensive data through the OVD Initiatives, the IRS whistleblower program, bilateral double tax treaty, tax information agreements and informal cooperation agreements with other countries, the New Program enables Swiss Banks...
...dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and defends) clients and their advisors to legally disclose (and legitimize) foreign accounts. For...
...banks, investment funds and insurance companies to report to the IRS Americans’ offshore accounts worth more than $50,000. It was enacted after a Swiss banking scandal showed U.S. taxpayers hid...
...Taxpayer Advocate Service’s (TAS) recommendation to expand the Streamlined Nonresident Filing Initiative to both U.S. residents and those owing more than $1,500, IRS officials publicly announced the IRS had eliminated...
...for US gift and estate tax purposes. Pre-immigration estate tax planning in this context means pre-domiciliary estate planning. Because of the limited scope of the US gift tax in the...
