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Tag: penalties and interest

Foreign Account Penalties Are Unfair

8 July, 2011

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

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IRS Announces “Good Faith” 90 Day Extension of Voluntary Disclosure Deadline

8 June, 2011

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

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Numerous Criminal Prosecutions of Taxpayers with Unreported Offshore Accounts

1 June, 2011

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

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HSBC and NRI Bank Accounts: Could It Spread to Other Banks?

16 May, 2011

The US Internal Revenue Service (IRS) has asked HSBC Bank to provide information on incomes of US residents who may be using accounts in India to evade income taxes. The move has raised several questions.

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Time Running Out for HSBC India accountholders sought by IRS

28 April, 2011

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.

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HSBC Expected to Disclose Account Holders Names

19 April, 2011

The IRS has petitioned for a federal court authorization to enable it to obtain information on HSBC Bank’s American account holders using their foreign accounts to evade taxes.  Most of these account holders are believed

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Post IRS Audit Strategic Options: The IRS’ 30 Day Letter

9 April, 2011

If, after conducting the audit, a taxpayer and revenue agent cannot come to an agreement, the agent will prepare and submit to the taxpayer a preliminary notice of deficiency, or “30-day letter.” The 30-day letter is

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Financial Crimes Enforcement Network (FINCEN) Issue Final Rules

21 March, 2011

The Bank Secrecy Act (“BSA”) was originally enacted in 1970 to help detect and prevent money laundering. The BSA requires reporting for a calendar year called a “Report of Foreign Bank and Financial Accounts” (Form

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2011 Offshore Voluntary Disclosure Initiative (OVDI)

11 February, 2011

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

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IRS Launches Second Offshore Voluntary Disclosure Initiative After Successful Prosecution

8 February, 2011

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

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Asset Protection for Physicians

1 April, 2010

Where physicians are most likely to lose wealth is through bad marriages, bad investments, bad tax planning, or a combination thereof.

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Pennsylvania’s 2010 Tax Amnesty Program

5 February, 2010

Our firm recently successfully filed several client's state amnesty applications.

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