Tag Archives: FBAR
Government Report Advises IRS to Increase Awareness of Offshore Account Rules to Help Immigrants
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 report Friday by the Government
COURT AUTHORIZES SERVICE OF JOHN DOE SUMMONS SEEKING THE IDENTITIES OF U.S. TAXPAYERS WITH OFFSHORE ACCOUNTS AT CIBC FIRSTCARIBBEAN INTERNATIONAL BANK
WASHINGTON – The Justice Department announced that late yesterday a federal court in San Francisco entered an order authorizing the Internal Revenue Service (IRS) to serve a John Doe summons seeking information about U.S. taxpayers who may hold offshore accounts
Quiet or Silent Disclosure Commentary from the Government Accountability Office
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 recommendations could put some taxpayers
Silent Disclosure: The Qualified Amended Return (QAR)
Can I Disclose Issues to the IRS After the Tax Return Is Filed? This question is very important for our clients exploring silently disclosing previously unreported income on an amended income tax return. The general rule is that taxpayers are
Another Local New Jersey client of HSBC India Pleads Guilty
A local New Jersey client of HSBC Holdings Plc (HSBA) last month pleaded guilty to evading taxes on $1.2 million in income and using an account in India to hide some of his money. This is at least the second
How to Defend Against FBAR Penalties
Following the IRS’ successful 2009 and 2011 offshore voluntary compliance initiatives, tax professionals should expect an increase in IRS examination activity of taxpayers who did not enter into these compliance initiatives. Approximately 30,000 taxpayers entered into the initiatives. There are
Foreign HSBC Bank Customer Avoids Jail: Given Three Years’ Probation
A Wisconsin neurosurgeon convicted of tax charges related to a HSBC bank accounts owned abroad that held $8.76 million was spared prison and ordered to serve three years’ probation, according to the Internal Revenue Service. Arvind Ahuja was sentenced yesterday
National Taxpayer Advocate Criticizes IRS over handling of offshore voluntary disclosures
The 2012 National Taxpayer Advocate (NTA) Annual Report to Congress criticized current IRS practices in the Offshore Voluntary Disclosure Program (OVDP) that hinder voluntary compliance by penalizing taxpayers who are entitled to a reasonable cause exception from willfulness. One of
National Taxpayer Advocate Identifies OVDP Program as a Serious Problem
On January 17 that National Taxpayer Advocate Nina Olson recently issued her 2012 Annual Report to Congress calling on Congress to simplify the Tax Code. In her report, Olson questioned the “one-size-fits-all” approach of the IRS Offshore Voluntary Disclosure Program
HSBC Payment of Largest Penalty and FATCA Encourages Taxpayers to Disclose
Last month, HSBC Holdings agreed to pay $1.92 billion in fines to U.S. authorities, which is the largest collective settlement in the Treasury Department’s history. The penalty assessment was based upon HSBC’s conduct in violation of the Bank Secrecy Act
Another HSBC Customer Likely Going to Jail
Last week a New Jersey client of HSBC Holdings Plc (HSBA) pleaded guilty to charges that he hid as much as $4.7 million through Swiss and Indian accounts not declared to the U.S. Internal Revenue Service. Sanjay Sethi, 52, who
New Comments of the IRS’ New Streamlined Filing Compliance Procedures for Non-Resident Non-Filer U.S. Taxpayers
I just returned from the American Bar Association Section of Taxation’s annual National Institute on Criminal Tax Fraud in Las Vegas. A topic of discussion was the relatively new New Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer U.S. Taxpayers (see
2012 Offshore Account Criminal Tax Cases
The Department of Justice continues to prosecute cases involving United States taxpayers who have failed to report their interests in offshore accounts. Most of the cases are for large offshore accounts, but they provide good guidance for what the US government
Top 10 factors to consider before deciding to opt out of OVDI or OVDP
While opting out of the OVDI or OVDP amnesty programs may result in a reduction of penalties that may otherwise be assessed, the taxpayer needs to carefully weigh the numerous consequences before doing so. Responsible tax professionals should discuss the
Foreign Account Tax Compliance Act (FATCA): More Information Sharing Agreements Expected
FATCA was enacted in 2010 by Congress to target non-compliance by U.S. taxpayers using foreign accounts. FATCA requires foreign financial institutions (FFIs) to report to the IRS information about financial accounts held by U.S. taxpayers, or by foreign entities in
2 recent IRS developments that will impact Indian Americans
Our firm was quoted last week in the Times of India newspaper: 2 recent IRS developments that will impact Indian Americans Deepa Venkatraghvan Sep 10, 2012, 07.54PM IST In the last few years, the US Internal Revenue Service (IRS) has been focusing heavily
New EZPASS OVDP Without Any Penalties for Non-Resident U.S. Taxpayers
Yesterday, as expected, the IRS announced its new New Filing Compliance Procedures for Non-Resident U.S. Taxpayers that taxpayers presenting “low compliance risk” should file delinquent tax returns, including delinquent information returns, for the past three years; and delinquent FBARs for the past
Instructions for New Streamlined Filing Compliance Procedures for Non-Resident, Non-Filer U.S. Taxpayers
The IRS has announced its new New Filing Compliance Procedures for Non-Resident U.S. Taxpayers that taxpayers presenting “low compliance risk” should file delinquent tax returns, including delinquent information returns, for the past three years; and delinquent FBARs for the past six years.
Another foreign bank customer found guilty of foreign income under-reporting and FBAR violations.
A doctor has been convicted of failing to disclose to US federal authorities that he maintained offshore HSBC bank accounts in India and France and hid approximately $8 million in secret foreign bank accounts. Dr. Arvind Ahuja of Wisconsin was
The “Quiet” or “Silent” Disclosure
Our office consults with many clients in determining whether they need to enter into the 2012 IRS Offshore Voluntary Disclosure Program. Because of the high 27.5% penalty in the 2012 OVDP program, many of our clients are considering alternative options
IRS Publishes Useful Chart Outlining Compliance Options for Offshore Assets
The IRS has recently published a useful chart outlining options available to help US taxpayers with offshore interests. The new IRS chart correctly states that it “recognizes that its focus on offshore enforcement efforts and related disclosure programs has raised
To Opt Out or Not Opt Out: That is the Question
When is it appropriate to make a quiet disclosure vs. making a disclosure through the Offshore Voluntary Disclosure Program? This question is not necessarily easy to answer. IRS agents handling OVDI/OVDP cases do not have discretion regarding offshore-related information return
Explore the OVDI opt-out option: Argue for Penalty Mitigation
The revised IRS OVDP FAQs offer helpful guidance on the opt-out option. The newly revised FAQs illustrate the pros and cons of opting out with six examples. See FAQ 51. The examples describe situations in which it may be smart
Opting Out of the OVDI Program: Argue for No Penalty and a Warning Letter
The revised IRS OVDP FAQs offer helpful guidance on the opt-out option. The newly revised FAQs illustrate the pros and cons of opting out with examples. Depending on the circumstances, we sometimes recommend some clients to opt out of the
Full Analysis of Updated 2012 OVDP Program
The Internal Revenue Service announced on June 26, 2012 (IR-2012-64) that it is tightening eligibility requirements for the open-ended offshore voluntary disclosure program (2012 OVDP) that it announced in January 2012 for taxpayers with unreported income or assets, generally in
IRS offers tax opportunity to Americans living abroad
Many Americans (including US citizens and US green card holders) living abroad will get a small reprieve from U.S. Internal Revenue Service rules on reporting foreign assets, the agency announced on Tuesday. The IRS said it would allow some U.S.
OVDP Ineligibility Possibility Increases
Yesterday the IRS stated that taxpayers’ eligibility to participate in the OVDP could be terminated if the foreign institution where you have your account faces IRS action. Once the U.S. government has taken action against a financial institution, any U.S.
IRS Announces Penalty Mitigation for Smaller US Taxpayers Living Abroad
The Internal Revenue Service appears to have finally created a process to finally separate small non-resident (foreign resident) US taxpayers from larger non-resident US taxpayers at the front end, and not force everyone through the OVDI/OVDP programs. Yesterday, the IRS
OVDI: Requesting issuance of a FBAR warning letter instead of penalties
In a Tax Notes Today report of statements made at the Eastern Pennsylvania Working Together Conference in Malvern, PA, Jason Kuratnick, IRS Associate Area Counsel (Philadelphia), Small Business / Self-Employed Division is reported to have said: The IRS may send
Opting-out of the Offshore Voluntary Disclosure Initiative: FBAR Penalty Mitigation Guidelines
Depending on the circumstances, we sometimes recommend some taxpayers to opt out of the voluntary disclosure initiative and allow us to demonstrate the absence of willfulness and avoid the normal FBAR penalty regime. We have been aggressively pursuing OVDI opt-outs
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