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Tag: amnesty

New Leak of Offshore Accountholders Highlights the Need to Clean Up

5 April, 2016

The U.S. Justice Department is reviewing reports about the offshore financial arrangements of global politicians and public figures based on 11.5 million leaked files from Panamanian law firm Mossack Fonseca, a department spokesman said yesterday.

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Streamlined Filing Compliance Procedure’s New Revisions to Streamlined Domestic Offshore Procedures (SDOP)

28 March, 2016

In the midst of tough tax season, many U.S taxpayers are unfortunately surprised to discover that they have a U.S. tax reporting obligation on financial accounts or assets held overseas. Once they discover their tax

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New IRS guidance Announced for IRS Streamlined Offshore Procedures.

28 January, 2016

In the midst of tough tax season, many U.S taxpayers are unfortunately surprised to discover that they have a U.S. tax reporting obligation on financial accounts or assets held overseas. Once they discover their tax

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What is a “FATCA Compliance Certificate”?

7 December, 2015

Many foreign banks and financial institutions have recently been asking customers for a “FATCA Compliance Certificate”.  The reason for the request is that your country and the US probably signed an agreement to implement the Foreign

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Protective Filing of Information Returns

27 November, 2015

There is an increased focus by the Internal Revenue Service (IRS) on offshore activities.  There are tax return and information return filing obligations that may be associated with foreign income, assets and transactions. Many taxpayers

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ABA COMMENTS ON THE 2014 OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS

30 October, 2015

We are members of the American Bar Association Section of Taxation, which recently submitted comments to the IRS on the IRS Offshore Voluntary Disclosure Program (“OVDP”), the Streamlined Domestic Offshore Program (“SDOP”), and the Streamlined Foreign Offshore

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Information Sharing of Account Holder Information Officially Begins

7 October, 2015

The IRS has begun receiving information regarding tax year 2014 from nations around the world who have agreed to comply with FATCA.  Some of those countries negotiated reciprocal agreements to also receive information from the

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Caution: Foreign Businesses Require Additional Reporting

28 September, 2015

If you are an American entrepreneur with a foreign business interest or operating abroad then you should be aware of U.S. tax reporting obligations on non-U.S. businesses. If a U.S. taxable person (U.S. citizens or

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IRS delinquent FBAR submission procedure

11 September, 2015

Last spring, the IRS revised its program for delinquent FBAR returns. The IRS offers a new “delinquent FBAR submission procedure”.  See below excerpt from the IRS website.The program is available if you properly reported on

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Correcting Common FBAR Errors

4 August, 2015

The IRS offers four options to fix FBAR mistakes. Participation in the two formal disclosure programs is permitted only if the funds held in the foreign financial account(s) are from a legal source (and not

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Taxpayers’ Evidence of Non-Willfulness or Willfulness Factors

13 July, 2015

We have come across the below 3 questions numerous times with our clients. What kind of evidence is relevant to demonstrate “non-willfulness” for purposes of the SDOP and the SFOP when the definition of non-willful

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India and US signed FATCA Agreement Today

9 July, 2015

India and the US today signed an agreement to implement the Foreign Account Tax Compliance Act (FATCA) that will facilitate exchange of information between the two countries starting on October 1, 2015. FATCA was signed

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