IRS expands use of Subpeonas
The U.S. Internal Revenue Service is planning to broaden the use of subpoenas of documents in cases where the name of a taxpayer under investigation is not known. The so-called John Doe summonses were a
Another Taxpayer Found Guilty of Failure to File FBARs and Report Foreign Income
Raju Mukhi of St. Louis MO was indicted last year for his alleged failure to file a report to the IRS on his foreign financial accounts and for filing false tax returns. United States citizens
Helpful Non-willful FBAR penalty case decided by court
For the first time, in the case of James Moore, Plaintiff v. United States of America, Defendant (James Moore v. U.S. Case 2:13-cv-02063-RAJ filed 4/1/15), we finally get a look at some non-willful FBAR penalty
Beware: India to sign FATCA agreement with US for sharing of information
Earlier this week, the Indian Cabinet, chaired by Prime Minister Narendra Modi, approved signing of an Inter-Governmental Agreement (IGA) between India and the U.S. for implementation of the U.S. Foreign Account Tax Compliance Act (FATCA). Indian
Another Customer with Unreported Offshore Bank Accounts Pleads Guilty
George Landegger, CEO of pulp and paper company, pleaded guilty last week in New York to a federal charge of failing to file a required report to the IRS about the account. He admitted that
Internal Revenue Service announces new International Data Exchange Service: The Beginning of Information Sharing
The Internal Revenue Service announced this week the opening of the International Data Exchange Service (IDES) for enrollment. Financial institutions and host country tax authorities will use IDES to securely send their information reports on
IRS Streamlined Filing Compliance Procedures Seminar
The Internal Revenue Service announced major changes in its offshore voluntary compliance programs, providing new streamlined filing compliance procedures to help both taxpayers residing overseas and those residing in the United States. The streamlined filing
IRS Releases FAQs for the Delinquent International Information Return Submission Procedures
The IRS recently released frequently asked questions for the Delinquent International Information Return Submission Procedures (available here). The IRS now states that these procedures are available to taxpayers even if they have unreported income. See below
New Report: Delinquent Taxpayers Could be Identified at US Border Crossings
The Internal Revenue Service’s collection efforts need to be improved to make sure that delinquent taxpayers residing in foreign countries comply with their U.S. tax obligations, according to a new government report. The report, from the
OVDP New Forms Announced by IRS
The IRS has simplified the process of entering the OVDP Program by issuing the following forms: Form 14457 – Offshore Voluntary Disclosure Letter Form 14454 – Offshore Voluntary Disclosure Program Letter Attachment The new forms (the old
How to Demonstrate Non-Willfulness Under The Streamlined Filing Compliance Procedures
The IRS recently announced Streamlined Filing Compliance Procedures in an effort to encourage U.S. taxpayers to come into compliance with their reporting and filing requirements associated with varying interests in foreign financial accounts and assets.
New IRS Disclosure Program Announced for Non-Resident Taxpayers: Streamlined Foreign Offshore Procedures
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