American Citizens Abroad (ACA) has written to IRS Commissioner Doug Shulman of the IRS to express the organization’s profound concern that he has not answered the Directive issued by National Taxpayer Advocate Nina Olson. In her report to Congress issued
The United States Senate has passed a provision in proposed legislation that would allow the State Department to deny, limit or revoke passports to citizens with “seriously” delinquent taxes. The passport provision is part of the Fight Offshore Tax Abuses
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
The announcement by the IRS of the opening of the new Offshore Voluntary Disclosure Program (OVDP) on January 9, 2012 came as a surprise to most tax practitioners, especially since the 2011 OVDI just ended on September 9, 2011. However,
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
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
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
As expected, the United States Internal Revenue Service (IRS) has disclosed that the recently-completed offshore voluntary offshore initiative (OVDI) has pushed the total number of voluntary disclosures up to 30,000 since 2009. The IRS customarily publicizes (and celebrates) such accomplishments.
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
Last week, late on Friday afternoon, August 26, 2011, the IRS issued a statement indicating that the due date for filing 2011 Offshore Voluntary Disclosure Initiative (OVDI) requests has been extended until September 9, 2011, due to the potential impact
If the US dollar is as close as we have come to a global currency — accepted everywhere from Fifth Avenue boutiques to Coca-Cola stands in Afghanistan — why are some American citizens finding it hard to put their money
Our office is a proud member of the New York State Bar Association (NYSBA) after reading their tax section’s detailed comments on the OVDI program. This is not an anti-tax group or self-interested association with radical comments on the OVDI
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
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
On July 14, 2011, Credit Suisse received a letter notifying it that it is a target of a Justice Department investigation. A target letter is significant. It likely means that a considerable level of investigation has already been done and further criminal investigation
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
Our office is advising dozens of clients (including many HSBC customers) regarding offshore accounts, all of whom may be subject to large unfair penalties. Finally it appears that someone in government is realizing the unfairness of the offshore penalties. In
The IRS last week explained fully the possibility of opting-out of the OVDI and taxpayers’ taking their chances with an IRS examination, particularly where the non-disclosure of assets or income could be proved to not be “wilful”, and has also
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.
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
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.
An Indian-American businessman on Tuesday pleaded guilty to conspiring to defraud US tax authorities by hiding his bank accounts in HSBC India, a case which has led the IRS to probe NRIs holding accounts in the bank. Vaibhav Dahake, 44
Foreign bank account reports (FBARs) for 2010 are due on June 30, 2011 (and no extension is available). Recent guidance provides insight into who is required to file an FBAR and what is considered to be a “foreign financial account”
Last week the U.S. Justice Department asked a federal district court in San Francisco to force HSBC USA to disclose the names of their U.S. customers suspected of having secret bank accounts in India. The legal action comes after the
you should assume that the IRS will eventually be informed of your foreign account, and criminal prosecution for non-disclosure and non-reporting will likely follow
We have reviewed the new 2011 OVDI FAQs and noticed that the Service has refined and streamlined the voluntary disclosure process. Our firm prepared dozens of voluntary disclosure applications in 2009 and the new 2011 FAQs seem to resolve some
On February 8, 2011, the IRS announced the 2011 Offshore Voluntary Disclosure Initiative (OVDI), designed to bring offshore money back into the U.S. tax system and help people with undisclosed income from hidden offshore accounts get current with their taxes.
After a successful indictment of a New Jersey man with HSBC Bank accounts in India, the IRS introduced a new Voluntary Disclosure Program on February 8, 2011 for U.S. taxpayers with undisclosed offshore accounts. Last week, according to an indictment
HSBC, one of the largest banks international banks in the world, is facing rough time with allegations on its holding bankers being involved with a New Jersey Indian American businessman in hiding his bank accounts in India from the Internal
