hsbc – Page 2 – Tax, Estate Planning & Probate Law Center

Foreign HSBC Bank Customer Avoids Jail: Given Three Years’ Probation

10 Mar 13

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 Identifies OVDP Program as a Serious Problem

01 Feb 13

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

30 Jan 13

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

11 Jan 13

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

Top 10 factors to consider before deciding to opt out of OVDI or OVDP

09 Oct 12

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

2 recent IRS developments that will impact Indian Americans

16 Sep 12

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

Another foreign bank customer found guilty of foreign income under-reporting and FBAR violations.

25 Aug 12

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

21 Aug 12

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

Full Analysis of Updated 2012 OVDP Program

15 Jul 12

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

11 Jul 12

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.

Should I close my foreign account?

23 Apr 12

Suppose you have a foreign bank account holding more than $10,000. You may have inherited it, used it to hide money during a dispute with your spouse or business partner, or just done it on a whim. As you try

Form 8938, FATCA, FBAR and penalties for all (including bankers)

05 Apr 12

The IRS and US Treasury have stepped up their efforts toward tracking down delinquent tax payers and enforcing payment of overdue taxes. One of these initiatives is the “Foreign Account Tax Compliance Act”. FATCA is part of the Hiring Incentives

Eleven foreign financial institutions to share their US customer account information

25 Mar 12

US authorities have offered eleven financial institutions a settlement agreement in which the US government’s investigations in those financial institutions — for aiding tax evasion — and potential prosecution would be dropped. The eleven financial institutions are: 1. Credit Suisse

New IRS Form 8938 Statement of Foreign Financial Assets is causing significant confusion

09 Mar 12

As anticipated, IRS Form 8938 Statement of Foreign Financial Assets is causing significant confusion among taxpayers attempting to complete these Forms for filing. Form 8938, Statement of Specified Foreign Financial Assets, is a new reporting form, which will be used to

Analysis of the new 2012 Offshore Voluntary Disclosure Program (OVDP)

10 Jan 12

Yesterday the Internal Revenue Service opened its Offshore Voluntary Disclosure Program (OVDP) to encourage more taxpayers with assets in undeclared foreign bank accounts to come forward. While the OVDP was not expected by most tax lawyers and professionals, it may

Another Bank Discloses Accountholders: Credit Suisse to Turn Over U.S. Account Data

28 Nov 11

Earlier this month Credit Suisse Group AG, Switzerland’s second-biggest bank, told U.S. clients it is giving confidential client account data to the Swiss tax authorities, who will decide whether to disclose it to the Internal Revenue Service. The U.S. is

Fifth HSBC India Customer indicted for tax evasion this year

19 Nov 11

A federal grand jury in San Jose, California, last week indicted Ashvin Desai of San Jose on three counts of tax evasion, two counts of willfully aiding the preparation of materially false tax returns and three counts of failing to

The Risks of “Opting Out” of OVDI

29 Oct 11

Under the 2011 OVDI voluntary disclosure program, the penalties for failing to timely file Foreign Bank Account Reports, (FBAR’s) and the penalties for failure to file information returns (such as Controlled Foreign Corporation tax returns) were combined into a single

What if You Missed the OVDI Deadline?

07 Oct 11

Although the OVDI program has expired, a U.S. taxpayer can still make a voluntary disclosure of foreign accounts pursuant to the IRS’s general voluntary disclosure policy. For over 50 years, the IRS has maintained a voluntary disclosure policy, under which

HSBC India Customer New Indictment Uncovers More HSBC Details

29 Sep 11

A Wisconsin neurosurgeon was re- indicted by a U.S. grand jury on new charges that he failed to declare an HSBC Holdings Plc (HSBA) account in India valued in 2009 at $8.7 million. Arvind Ahuja was indicted again by a

With No More Amnesty Program: Explore the IRS’s Traditional Voluntary Disclosure program

14 Sep 11

Even though the deadline for the Internal Revenue Service’s 2011 Offshore Voluntary Disclosure Initiative has concluded last week, U.S. taxpayers with undisclosed offshore accounts still have the opportunity to come forward through the IRS’s traditional Voluntary Disclosure program. Like the

One Month Countdown: The Deadline is Nearing for U.S. Taxpayers with Undisclosed Accounts to Come Forward

01 Aug 11

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 with undisclosed offshore accounts to

New Online System for Filing Your Report of Foreign Bank and Financial Accounts (FBAR)

19 Jul 11

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) on Monday said it has developed an electronic filing system for Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR). The reports can now be filed via FinCEN’s BSA E-Filing

“Willfulness” When Deciding Whether to Opt Out of 2011 OVDI

11 Jul 11

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 failure to file the FBAR

What HSBC India Accountholders Can Expect From the IRS

09 Jul 11

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 account information (including names, addresses,

IRS Announces “Good Faith” 90 Day Extension of Voluntary Disclosure Deadline

08 Jun 11

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 made a good faith attempt

Numerous Criminal Prosecutions of Taxpayers with Unreported Offshore Accounts

01 Jun 11

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 aggressive investigations and enhanced scrutiny.

Latest Guilty Plea for an Another HSBC Offshore Bank Accountholder

22 May 11

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 relatively small amounts of income,

Another U.S. taxpayer with an offshore HSBC bank account pleads guilty

01 May 11

On April 13, 2011, another U.S. taxpayer with an offshore HSBC bank account, Josephine Bhasin (United States v. Bhasin, E.D.N.Y., No. 11-cr-00268-ADS), pled guilty to charges of knowingly filing false tax returns, false amended tax returns, and false FBARs. According

Time Running Out for HSBC India accountholders sought by IRS

28 Apr 11

If HSBC produces these records, which is likely, it may be too late for U.S. taxpayers with undisclosed HSBC accounts to take advantage of the IRS Voluntary Disclosure Program for offshore accounts.

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