offshore accounts – Page 3 – Tax, Estate Planning & Probate Law Center

New IRS Disclosure Program Announced for Non-Resident Taxpayers: Streamlined Foreign Offshore Procedures

21 Jun 14

The United States’ IRS is moving to entice more taxpayers to disclose their unreported assets and income just weeks before implementation of the U.S. Foreign Account Tax Compliance Act (FATCA). The IRS has announced a Streamlined Foreign Offshore Procedures (SFOP),

IRS Announces Major New changes to the Offshore Voluntary Disclosure Program

18 Jun 14

The IRS today made significant changes to its offshore voluntary compliance programs, with the intent of providing new options to help both taxpayers residing overseas and those residing in the United States. The agency says the changes are anticipated to provide

New Streamlined Domestic Offshore Procedures (SDOP) is a Game Changer

18 Jun 14

The IRS has announced a Streamlined Domestic Offshore Procedures (SDOP), which will significantly alter all future voluntary disclosures. The SDOP is a game changer for residents and non-resident (who would use the Streamlined Foreign Offshore Procedures (SFOP)) taxpayers alike. The

FBAR Reporting Season is here

16 Jun 14

All taxpayers are reminded about FBAR reporting this year, as the process has changed. If you have a financial interest in or signature authority over a foreign financial account, including a bank account, brokerage account, mutual fund, trust, or other

New offshore voluntary disclosure program (OVDP) changes expected to be favorable to taxpayers

09 Jun 14

During Internal Revenue Service (IRS) Commissioner John Koskinen’s remarks at a speech before the United States Council-OECD International Tax Conference in Washington last week, he indicated that the agency is preparing a new offshore voluntary disclosure program (OVDP) that will

FATCA-Compliant Institutions List Goes Online

03 Jun 14

While over 77,000 banks and financial institutions have registered under FATCA—the Foreign Account Tax Compliance Act, the Internal Revenue Service has introduced an online tool that will allow users to check on whether a foreign financial institution has registered for

IRS Reminds (again) Taxpayers to Report Foreign Income and Assets

30 Apr 14

Earlier this month on April 11, 2014, the Internal Revenue Service issued Notice IR-2014-52 reminding U.S. citizens and resident aliens, including those with dual citizenship who have lived or worked abroad during all or part of 2013, that they may have a

Most Swiss banks participating in the US Department of Justice (DOJ) amnesty program seek extension to disclose

28 Apr 14

By April 30, 2014, unless granted a 60-day extension, all Swiss banks participating in the US Department of Justice (DOJ) amnesty program will be required to provide substantial client information on its US account holders. We have previously posted on

Republican Party Rallies Against FATCA: Success Unlikely

22 Feb 14

The Republican Party is expected to approve a resolution calling for repeal of an Obama administration law that is designed to crack down on offshore tax dodging. In what would be the party’s first appeal to scrap the law -the

No More Delays for FATCA: Get Ready for Disclosure

13 Feb 14

The US Foreign Account Tax Compliance Act (FATCA) will definitely come into effect on 1 July this year with no possibility of further delay, according to officials of the US Internal Revenue Service (IRS). FATCA, which was signed in March

Canada and US sign FATCA tax deal where banks to share information with IRS

06 Feb 14

Ottawa and Washington have reached a compromise over how to apply a U.S. law targeting would-be American tax dodgers living in Canada. Canada has signed an agreement with the U.S. on the automatic sharing of bank information between the two

Swiss Bank Disclosure Round Up

02 Jan 14

A host of Swiss banks have signaled their readiness to work with U.S. officials in a crackdown on wealthy Americans evading taxes. Many more are expected to follow in the coming weeks, as Switzerland’s cherished bank secrecy slowly gets wound back.

More Swiss Banks Agree to Cooperate with the IRS

31 Dec 13

Lombard Odier & Cie and VP Bank (Switzerland) last week became the latest Swiss banks to say they would work with U.S. officials in a crackdown on lenders suspected of helping wealthy Americans evade taxes through hidden offshore accounts. Unlisted

Argue for No Penalty and a Warning Letter for FBAR Violations

22 Dec 13

The IRS may send a warning letter in lieu of asserting penalties for failure to file a Form TD F 90-22.1, “Report of Foreign Bank and Financial Accounts,” if it would be sufficient to bring the individual into compliance, an

US Department of Justice Encourages Swiss banks to Disclose Information

15 Dec 13

Last week the Tax Division of the Department of Justice strongly encouraged Swiss banks that want to seek non-prosecution agreements to resolve past cross-border criminal tax violations to submit letters of intent by the Dec. 31, 2013 deadline required by

More Swiss Banks Agree to Disclose US Customers Accounts: Expect More Customer Letters to be Sent

12 Dec 13

As of yesterday, three Swiss banks have agreed to participate in a U.S. disclosure program aimed at lenders suspected of aiding tax evasion by Americans. Many more expected and thousands of letters are being sent to US customers with Swiss

Comparison of Form 8938 and FBAR Requirements

09 Dec 13

The new Form 8938 filing requirement does not replace or otherwise affect a taxpayer’s obligation to file FinCEN Form 114 (Report of Foreign Bank and Financial Accounts). Individuals must file each form for which they meet the relevant reporting threshold.

IRS Announces New Rules for FBAR Penalties

27 Nov 13

There are two types of penalties applicable to FinCEN Form 114 (Report of Foreign Bank and Financial Accounts) (FBARs): (1) Non-Willful and (2) Willful. The penalties are theoretically assessed per account and not per FBAR; however, in practice, our firm

IRS Official Announces New Focus on Offshore Assets in Indian Banks

20 Nov 13

Reporting on a California State Bar Tax Section Meeting, Tax Notes reports that the IRS will soon (as early as the week of 11/11/13) ) “begin examining U.S. taxpayers suspected of holding undeclared accounts in Indian banks, according to Nicholas

Swiss Government and US Government Announce New Program for Cooperation and Disclosure by Swiss Banks

12 Sep 13

In August 2013, the Swiss Federal Government and the DOJ announced a first of its kind program (the New Program) that will enable eligible Swiss banks to address and resolve their status with regard to the DOJ’s ongoing enforcement investigations. The

Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP) opt-out results and updates

12 Sep 13

Many of our clients are carefully considering OVDI opt-outs. The opt out option became first available during the 2011 OVDI program, and continues with the current OVDP program. The 2012 OVDP program continues the procedures announced in 2011 regarding decisions to “opt

Foreign Account Tax Compliance Act (FATCA) online registration program is launched

26 Aug 13

The Internal Revenue Service on Monday launched an online registration program for the hundreds of thousands of financial firms around the world that must comply with a U.S. anti-tax evasion law or risk being shut out of financial markets. Starting

IRS Offshore Voluntary Disclosure Programs Continue to Burden “Benign Actors” and Damage IRS Credibility

23 Jul 13

The Taxpayer advocate has issued a new mid-year 2013 report. The portion that relates to the IRS’s OVDI/P initiatives is posted below (footnotes and tables omitted). The IRS offered a series of offshore voluntary disclosure (OVD) programs to settle with

Reasons to Opt Out of the 2011 OVDI Program

18 Jun 13

Top 4 Reasons to Opt Out of the 2011 OVDI Program 1. The IRS Taxpayer Advocate’s Report: Although the IRS has not closed very many opt-out cases, the average civil FBAR penalty assessed against those opting out of the 2009 OVDP

FBAR Deadline is June 28, 2013

12 Jun 13

This month we remind taxpayers of the upcoming June 30, 2013 deadline for filing Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), to report financial interests in, or signature authority over, foreign financial accounts. There is

Finally: IRS Reminds Those with Foreign Assets of U.S. Tax Obligations

29 May 13

The IRS has finally decided that educating taxpayers and tax advisors of tax obligations of foreign assets and income would be helpful and encourage compliance. The recent education announcements appear to address the IRS’ alleged shortcomings in educating taxpayers with

HSBC Bank Expects Significant Penalties from US Government for Violations

18 May 13

Global bank HSBC has said it may face “significant” penalties from the US authorities with regard to an ongoing probe into suspected tax evasion by the US-based clients of its Indian unit, among other cases. The US tax department is

Finally. Government Accountability Office makes recommendations to the IRS for tax laws education to immigrants

15 May 13

In latest report from a government watchdog agency called the Government Accountability Office (GAO) the GAO makes recommendations to the IRS, and the IRS pays attention. Those recommendations could put some taxpayers in trouble, but some are beneficial. Particularly helpful tax laws education commentary

IRS’s four offshore programs have netted 39,000 taxpayers and over $5.5 billion

06 May 13

The Internal Revenue Service has collected over $5.5 billion in revenue from taxpayers who came forward and reported on their foreign holdings under its Offshore Voluntary Disclosure Programs, but it could be missing billions more in revenue from tax evaders,

Government Report Advises IRS to Increase Awareness of Offshore Account Rules to Help Immigrants

30 Apr 13

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

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