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Tag: Asset Protection

Another Customer with Unreported Offshore Bank Accounts Pleads Guilty

21 January, 2015

George Landegger, CEO of pulp and paper company, pleaded guilty last week in New York to a federal charge of failing to file a required report to the IRS about the account. He admitted that

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Internal Revenue Service announces new International Data Exchange Service: The Beginning of Information Sharing

17 January, 2015

The Internal Revenue Service announced this week the opening of the International Data Exchange Service (IDES) for enrollment.  Financial institutions and host country tax authorities will use IDES to securely send their information reports on

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New IRS Subpoenae and IRS Data Mining Expected

26 December, 2014

Last week a federal judge approved the IRS issuing “John Doe” summonses requiring FedEx, DHL, UPS, and numerous other intermediaries to produce information about U.S. taxpayers who used Sovereign Management & Legal Ltd. for offshore

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News from the 2014 Criminal Fraud and Tax Controversy Conference

22 December, 2014

We just returned last week from attending the Criminal Fraud and Tax Controversy Conference in Las Vegas, sponsored by the American Bar Association Section of Taxation where many government officials were in attendance. Below are

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IRS Releases Training Documents on Offshore Voluntary Disclosure Program

2 December, 2014

last month the IRS released more than 6,500 pages from the Internal Revenue Service on the agency’s Offshore Voluntary Disclosure Program and how it trains its agents. The documents included material used in training IRS personnel in

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IRS Streamlined Filing Compliance Procedures Seminar

23 November, 2014

The Internal Revenue Service announced major changes in its offshore voluntary compliance programs, providing new streamlined filing compliance procedures to help both taxpayers residing overseas and those residing in the United States. The streamlined filing

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Major changes to IRS offshore voluntary compliance programs

30 September, 2014

Many clients are asking our office about the new compliance solutions to clean up past errors in disclosing foreign assets. In June 2014, the IRS announced major changes to its offshore voluntary compliance programs, providing

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Citizenship renunciation fee increases as American expatriates flee FATCA

13 September, 2014

US government fees charged to Americans for renouncing their citizenship will rocket from $450 to $2,350 on September 12, 2014. The fivefold increase is probably related to the recent dramatic rise in renunciations triggered by

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Streamlined Procedures for U.S. Taxpayers Residing In the United States

27 August, 2014

Many of our clients are interested in the new Streamlined Filing Compliance Procedures, which were recently announced by the IRS. Therefore, we are providing more general information on the Procedures. General Eligibility: The modified Streamlined Filing Compliance

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IRS Official Provides Insights for the new IRS Streamlined Compliance Procedures

15 August, 2014

Taxpayers who are in the Offshore Voluntary Disclosure Program to report their overseas assets can request the favorable penalty structure under newly expanded streamlined compliance procedures without giving up the audit and criminal liability protection

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How to Demonstrate Non-Willfulness Under The Streamlined Filing Compliance Procedures

11 August, 2014

The IRS recently announced Streamlined Filing Compliance Procedures in an effort to encourage U.S. taxpayers to come into compliance with their reporting and filing requirements associated with varying interests in foreign financial accounts and assets.

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Taxpayer’s Beware: Proving Non-Willful Conduct in the new IRS Streamlined Filing Compliance Procedures

2 July, 2014

Taxpayers should think carefully before entering a new Internal Revenue Service program titled Streamlined Filing Compliance Procedures for offshore-account holders whose conduct was not “willful”. On June 18th, the IRS announced significant changes to its

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