...(SFFAs) when filing their federal income tax returns. The act was effective for tax years beginning after March 18, 2010; however, in Notice 2011-55, the IRS suspended the requirement until...
...IRS’ aggressive stance on tax enforcement of offshore activities. Patel Law Offices is a law firm dedicated to helping clients resolve complicated tax, criminal tax, and international tax problems. Our...
...disclose it to the Internal Revenue Service. The U.S. is probing whether Credit Suisse helped Americans evade taxes, and the IRS used a 1996 tax treaty to request data for...
...for U.S. taxpayers with undisclosed HSBC accounts to take advantage of the IRS Voluntary Disclosure Program for offshore accounts. The IRS says there are 9,000 high net worth Indian US...
...(No.51 ) discusses the basis upon which a taxpayer might “opt out” of the offshore voluntary disclosure program. The IRS uses the term “reasonable cause” in defining whether a taxpayer’s...
...should not reply. The IRS has asked that all unsolicited email claiming to be from the IRS be reported to phishing@irs.gov. Additional information can be located at the IRS website....
...or Frazzetto to hide their accounts. About 30,000 U.S. taxpayers have avoided prosecution since 2009 by voluntarily disclosing offshore accounts to the IRS. The Justice Department has interviewed many of...
...the IRS has maintained a voluntary disclosure policy, under which taxpayers can disclose, and rectify, any form of tax noncompliance. To make a voluntary disclosure, a taxpayer must make a...
...postmortem tax planning strategy, you need to keep an eye on the calendar. Starting in 2011, the tax-free amounts you can give to no-spousal heirs during life and at death...
...offshore tax evasion that includes grand jury investigations of eight foreign banks. Prosecutors have filed criminal tax charges against more than three dozen former U.S. clients of UBS AG and...
When the IRS says “voluntary” it can sound scary. The IRS is unlikely to use this word unless the potential liability is serious. The IRS would much rather have you...
...when (a) the taxpayer has shown a willingness to cooperate (and does cooperate) with the IRS in determining her correct tax liability and (b) the taxpayer makes good faith arrangements...
