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Opting-out of the Offshore Voluntary Disclosure Initiative: FBAR Penalty Mitigation Guidelines

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Opting-out of the Offshore Voluntary Disclosure Initiative: FBAR Penalty Mitigation Guidelines

19 May, 2012

...is a law firm 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...

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The legal standard of “willfulness”: Opt out to avoid high penalties

1 May, 2012

...IRS under the standard of clear and convincing evidence, which is a very high legal standard to establish. If the Taxpayer knew about the requirement to file, it would affect...

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Should I close my foreign account?

23 April, 2012

...now? If you didn’t disclose the account on your tax returns and owe tax from the past, you face a tough choice. Staying hidden forever seems unlikely and is highly...

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Global Enforcement of FATCA: Something to Worry About

14 April, 2012

...agreement directly with the IRS, provided that each FFI is registered with the IRS or is excepted from registration under the agreement or under IRS guidance. Allow FFIs established in...

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Difference between Form 8938 and FBAR Requirements

9 April, 2012

...treatment and disclosure of offshore assets. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our firm assists (and...

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Checklist of tax forms for taxpayers with foreign assets

9 April, 2012

...sometimes obscure U.S. tax forms that U.S. taxpayers are required to file, we have put together the following checklist to help you keep track of them. Form 8938 (New): Statement...

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IRS attempts to demystify its new Form 8938

8 April, 2012

...law firm 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...

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A limited opportunity for generous gift tax exclusions

7 April, 2012

...in lower income tax brackets, the gifting program may produce income tax savings. In addition, the gifted assets will avoid New Jersey estate tax because there is no gift tax...

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More Tax Complexity: New Form 8938

7 April, 2012

...IRS’ initial warning. Additionally, the IRS may apply a 40% penalty on the taxes from non-disclosed assets. Unlike many US taxpayer tax matters, the filing requirements leave little guess work....

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Form 8938, FATCA, FBAR and penalties for all (including bankers)

5 April, 2012

The IRS and US Treasury have stepped up their efforts toward tracking down delinquent tax payers and enforcing payment of overdue taxes. One of these initiatives is the “Foreign Account...

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Frequent Scenarios in Offshore Voluntary Disclosures

3 April, 2012

...more and more resources on international tax evasion techniques and tax evasion careful reporting is a must to avoid penalties, including penalties for tax evasion, tax fraud and FBAR penalties....

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Eleven foreign financial institutions to share their US customer account information

25 March, 2012

...January 9th, 2012, the IRS re-opened its Offshore Voluntary Disclosure Program (OVDP) to encourage US taxpayers with undisclosed offshore accounts to come into compliance. The 2012 Amnesty Program is in...

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