Swiss Bank Disclosure Round Up
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
U.S. Signs FATCA Pacts with Malta, Netherlands, Bermuda, Jersey, Guernsey and Isle of Man
Last week, the U.S. signed six more intergovernmental agreements with a half dozen jurisdictions, including several traditional offshore tax havens, to implement the Foreign Account Tax Compliance Act, or FATCA. Over the past week, the
US Department of Justice Encourages Swiss banks to Disclose Information
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.
Comparison of Form 8938 and FBAR Requirements
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
IRS Official Announces New Focus on Offshore Assets in Indian Banks
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
Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP) opt-out results and updates
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
New Taxpayer Advocate Service Report Discusses Optouts out of the OVDI/OVDP
The Taxpayer Advocate Service (TAS) has issued a new mid-year 2013 report. The TAS report discussion regarding optouts out of the OVDI/OVDP is interesting. For the 2009 OVDP (which was a smaller group of applications
Reasons to Opt Out of the 2011 OVDI Program
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
Opt Out of OVDI Program Penalties to Get a Lower Penalty
Under the 2011 Offshore Voluntary Disclosure Initiative (OVDI) or 2012 Offshore Voluntary Disclosure Program (OVDP), the 2012 program gives no discretion to the IRS agents to reduce penalties. If a participant does not believe that
IRS’s four offshore programs have netted 39,000 taxpayers and over $5.5 billion
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
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
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