FATCAts
If the US dollar is as close as we have come to a global currency — accepted everywhere from Fifth Avenue boutiques to Coca-Cola stands in Afghanistan — why are some American citizens finding it
One Month Countdown: The Deadline is Nearing for U.S. Taxpayers with Undisclosed Accounts to Come Forward
The deadline to enter a complete submission into the 2011 Offshore Voluntary Disclosure Initiative (OVDI) is August 31, 2011, only one month remains and time is running out. The OVDI provides an opportunity for taxpayers
In Addition to HSBC, Credit Suisse Also Being Investigated for Offshore Activities
On July 14, 2011, Credit Suisse received a letter notifying it that it is a target of a Justice Department investigation. A target letter is significant. It likely means that a considerable level of investigation has already been
“Willfulness” When Deciding Whether to Opt Out of 2011 OVDI
The IRS recently posted guidance in its OVDI FAQs (#51) whether taxpayers should opt out of the 2011 Voluntary Disclosure Initiative’s (the “OVDI”) civil penalty structure. Taxpayers who participate in the OVDI, but feel that their
What HSBC India Accountholders Can Expect From the IRS
Our firm recently informally met with a US Department of Justice official (name withheld because official was not authorized to officially speak) in Washington DC regarding the pending summons served on HSBC India to reveal
Foreign Account Penalties Are Unfair
Our office is advising dozens of clients (including many HSBC customers) regarding offshore accounts, all of whom may be subject to large unfair penalties. Finally it appears that someone in government is realizing the unfairness
Navigating Foreign Waters: The Complex Requirements of Foreign Accounts Compliance
Tomorrow night our firm will be presenting a three hour seminar to tax professionals on foreign account disclosure, FBARs, and OVDI at the Academy of Continuing Professional Education (ACPE): June 21, 2011 – 7:00 p.m.
Opting-out or Opting-in of OVDI
The IRS last week explained fully the possibility of opting-out of the OVDI and taxpayers’ taking their chances with an IRS examination, particularly where the non-disclosure of assets or income could be proved to not
IRS Announces “Good Faith” 90 Day Extension of Voluntary Disclosure Deadline
The IRS said last week that it is making available to taxpayers a 90-day deadline extension to participate in the 2011 offshore voluntary disclosure initiative (OVDI). The extension would be available to taxpayers who have
Numerous Criminal Prosecutions of Taxpayers with Unreported Offshore Accounts
The Department of Justice and local United States Attorneys’ Offices continue to zealously prosecute numerous cases involving U.S. taxpayers who have failed to report their interests in offshore accounts. The successful prosecutions underscore the government’s
Latest Guilty Plea for an Another HSBC Offshore Bank Accountholder
Last week a Boston venture capitalist and director at a Boston bank was charged with failing to report his foreign bank account and income to the US Department of the Treasury. It is noteworthy that
HSBC and NRI Bank Accounts: Could It Spread to Other Banks?
The US Internal Revenue Service (IRS) has asked HSBC Bank to provide information on incomes of US residents who may be using accounts in India to evade income taxes. The move has raised several questions.