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.
12 years ago the IRS created the first-time penalty abatement administrative waiver (FTA), which allows typically compliant individual and business taxpayers to request abatement, or removal, of certain penalties that the IRS has assessed against them
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,
We have previously posted on the U.S. Justice Department’s program offered to Swiss banks and targeted to identifying U.S. taxpayers that have not disclosed foreign accounts to the IRS. It has now been stated that
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
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
Swiss banks are pressuring current and former U.S. account holders to disclose undeclared assets to the Internal Revenue Service. In some cases, the banks are freezing accounts unless clients can prove they have declared the
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.
Last year, the IRS announced its third offshore voluntary disclosure initiative. Like the earlier initiatives, the 2012 OVDP is designed to encourage taxpayers with unreported offshore accounts and assets to voluntarily disclose them to the
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
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
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;
