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Tag: voluntary disclosure

New York State Bar Association Proposes OVDI Changes to IRS

12 August, 2011

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

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One Month Countdown: The Deadline is Nearing for U.S. Taxpayers with Undisclosed Accounts to Come Forward

1 August, 2011

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

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New Online System for Filing Your Report of Foreign Bank and Financial Accounts (FBAR)

19 July, 2011

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

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In Addition to HSBC, Credit Suisse Also Being Investigated for Offshore Activities

16 July, 2011

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

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“Willfulness” When Deciding Whether to Opt Out of 2011 OVDI

11 July, 2011

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

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What HSBC India Accountholders Can Expect From the IRS

9 July, 2011

Our firm recently informally met with a US Department of Justice official (name withheld because official was not authorized to officially speak) in Washington DC regarding the pending summons served on HSBC India to reveal

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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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Navigating Foreign Waters: The Complex Requirements of Foreign Accounts Compliance

20 June, 2011

Tomorrow night our firm will be presenting a three hour seminar to tax professionals on foreign account disclosure, FBARs, and OVDI at the Academy of Continuing Professional Education (ACPE): June 21, 2011 – 7:00 p.m.

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Opting-out or Opting-in of OVDI

9 June, 2011

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

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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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Latest Guilty Plea for an Another HSBC Offshore Bank Accountholder

22 May, 2011

Last week a Boston venture capitalist and director at a Boston bank was charged with failing to report his foreign bank account and income to the US Department of the Treasury. It is noteworthy that

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