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
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
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
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
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
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
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
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
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
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
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
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.
