voluntary disclosure – Page 4 – Tax, Estate Planning & Probate Law Center

No More Delays for FATCA: Get Ready for Disclosure

13 Feb 14

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, which was signed in March

Canada and US sign FATCA tax deal where banks to share information with IRS

06 Feb 14

Ottawa and Washington have reached a compromise over how to apply a U.S. law targeting would-be American tax dodgers living in Canada. Canada has signed an agreement with the U.S. on the automatic sharing of bank information between the two

US DOJ Tax Asst Attorney General Keneally Reports that One third of Swiss Banks Joining US DOJ Swiss Bank Program

29 Jan 14

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 that one-third of all Swiss

Swiss Bank Disclosure Round Up

02 Jan 14

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 secrecy slowly gets wound back.

More Swiss Banks Agree to Cooperate with the IRS

31 Dec 13

Lombard Odier & Cie and VP Bank (Switzerland) last week became the latest Swiss banks to say they would work with U.S. officials in a crackdown on lenders suspected of helping wealthy Americans evade taxes through hidden offshore accounts. Unlisted

U.S. Signs FATCA Pacts with Malta, Netherlands, Bermuda, Jersey, Guernsey and Isle of Man

28 Dec 13

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 U.S. Treasury Department has signed

Argue for No Penalty and a Warning Letter for FBAR Violations

22 Dec 13

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 the individual into compliance, an

Swiss Banks are Pressuring Customers to Disclose

21 Dec 13

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 account to the IRS—or that

US Department of Justice Encourages Swiss banks to Disclose Information

15 Dec 13

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. 31, 2013 deadline required by

Method to Cure Delinquent or Incomplete Foreign Information Returns Without Penalties

14 Dec 13

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 IRS. The 2012 OVDP is

More Swiss Banks Agree to Disclose US Customers Accounts: Expect More Customer Letters to be Sent

12 Dec 13

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 to US customers with Swiss

Comparison of Form 8938 and FBAR Requirements

09 Dec 13

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 meet the relevant reporting threshold.

IRS Announces New Rules for FBAR Penalties

27 Nov 13

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; however, in practice, our firm

IRS Official Announces New Focus on Offshore Assets in Indian Banks

20 Nov 13

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 Indian banks, according to Nicholas

New FinCEN Form 114 (FBAR) Filing Rules Announced

29 Sep 13

Responding to the needs of many filers who submit Reports of Foreign Bank and Financial Accounts (FBARs) jointly with spouses, or wish to submit them via third-party preparers, the Financial Crimes Enforcement Network (FinCEN) today introduced FinCEN Form 114(a), Record

Swiss Government and US Government Announce New Program for Cooperation and Disclosure by Swiss Banks

12 Sep 13

In August 2013, the Swiss Federal Government and the DOJ announced a first of its kind program (the New Program) that will enable eligible Swiss banks to address and resolve their status with regard to the DOJ’s ongoing enforcement investigations. The

Offshore Voluntary Disclosure Initiative/Program (OVDI/OVDP) opt-out results and updates

12 Sep 13

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 2011 regarding decisions to “opt

Foreign Account Tax Compliance Act (FATCA) online registration program is launched

26 Aug 13

The Internal Revenue Service on Monday launched an online registration program for the hundreds of thousands of financial firms around the world that must comply with a U.S. anti-tax evasion law or risk being shut out of financial markets. Starting

New Taxpayer Advocate Service Report Discusses Optouts out of the OVDI/OVDP

03 Jul 13

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 compared to 2011 OVDI), there

Reasons to Opt Out of the 2011 OVDI Program

18 Jun 13

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 out of the 2009 OVDP

Opt Out of OVDI Program Penalties to Get a Lower Penalty

13 Jun 13

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 he or she should have

Finally: IRS Reminds Those with Foreign Assets of U.S. Tax Obligations

29 May 13

The IRS has finally decided that educating taxpayers and tax advisors of tax obligations of foreign assets and income would be helpful and encourage compliance. The recent education announcements appear to address the IRS’ alleged shortcomings in educating taxpayers with

HSBC Customer Avoids Jail in Tax Evasion Case

23 May 13

A New Jersey businessman who cooperated with prosecutors avoided prison after admitting he conspired with five HSBC Holdings bankers to hide his Indian bank accounts from U.S. tax authorities. Vaibhav Dahake, 46, was sentenced to one year of probation yesterday

HSBC Bank Expects Significant Penalties from US Government for Violations

18 May 13

Global bank HSBC has said it may face “significant” penalties from the US authorities with regard to an ongoing probe into suspected tax evasion by the US-based clients of its Indian unit, among other cases. The US tax department is

IRS’s four offshore programs have netted 39,000 taxpayers and over $5.5 billion

06 May 13

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 in revenue from tax evaders,

Government Report Advises IRS to Increase Awareness of Offshore Account Rules to Help Immigrants

30 Apr 13

The Internal Revenue Service’s four amnesty programs for those who have undeclared offshore accounts have resulted in more than 39,000 disclosures by taxpayers and more than $5.5 billion in revenues as of December 2012. A report Friday by the Government

COURT AUTHORIZES SERVICE OF JOHN DOE SUMMONS SEEKING THE IDENTITIES OF U.S. TAXPAYERS WITH OFFSHORE ACCOUNTS AT CIBC FIRSTCARIBBEAN INTERNATIONAL BANK

30 Apr 13

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 who may hold offshore accounts

Quiet or Silent Disclosure Commentary from the Government Accountability Office

29 Apr 13

The recent report from a government watchdog agency called the Government Accountability Office (GAO) shows how well the IRS attack on offshore tax evasion is coming. The GAO makes recommendations to the IRS, and the IRS pays attention. Those recommendations could put some taxpayers

HSBC customer Josephine Bhasin Criminal Sentencing Very Light

20 Apr 13

HSBC customer Josephine Bhasin was sentenced last month. Josephine Bhasin of New York earlier pleaded guilty before U.S. Magistrate Judge E. Thomas Boyle in Central Islip, N.Y., to filing a false 2008 individual income tax return that did not report

Silent Disclosure: The Qualified Amended Return (QAR)

13 Apr 13

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 rule is that taxpayers are

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