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 of letters are being sent
The new Form 8938 filing requirement does not replace or otherwise affect a taxpayer’s obligation to file FinCEN Form 114 (Report of Foreign Bank and Financial Accounts). Individuals must file each form for which they
There are two types of penalties applicable to FinCEN Form 114 (Report of Foreign Bank and Financial Accounts) (FBARs): (1) Non-Willful and (2) Willful. The penalties are theoretically assessed per account and not per FBAR;
In August 2013, the Swiss Federal Government and the DOJ announced a first of its kind program (the New Program) that will enable eligible Swiss banks to address and resolve their status with regard to the
Top 4 Reasons to Opt Out of the 2011 OVDI Program 1. The IRS Taxpayer Advocate’s Report: Although the IRS has not closed very many opt-out cases, the average civil FBAR penalty assessed against those opting
The IRS has finally decided that educating taxpayers and tax advisors of tax obligations of foreign assets and income would be helpful and encourage compliance. The recent education announcements appear to address the IRS’ alleged
A New Jersey businessman who cooperated with prosecutors avoided prison after admitting he conspired with five HSBC Holdings bankers to hide his Indian bank accounts from U.S. tax authorities. Vaibhav Dahake, 46, was sentenced to
Global bank HSBC has said it may face “significant” penalties from the US authorities with regard to an ongoing probe into suspected tax evasion by the US-based clients of its Indian unit, among other cases.
In latest report from a government watchdog agency called the Government Accountability Office (GAO) the GAO makes recommendations to the IRS, and the IRS pays attention. Those recommendations could put some taxpayers in trouble, but some are beneficial. Particularly
The Internal Revenue Service has collected over $5.5 billion in revenue from taxpayers who came forward and reported on their foreign holdings under its Offshore Voluntary Disclosure Programs, but it could be missing billions more
The Internal Revenue Service’s four amnesty programs for those who have undeclared offshore accounts have resulted in more than 39,000 disclosures by taxpayers and more than $5.5 billion in revenues as of December 2012. A
The recent report from a government watchdog agency called the Government Accountability Office (GAO) shows how well the IRS attack on offshore tax evasion is coming. The GAO makes recommendations to the IRS, and the IRS pays attention. Those
