Depending on the circumstances, we sometimes recommend some taxpayers to opt out of the voluntary disclosure initiative and allow us to demonstrate the absence of willfulness and avoid the normal FBAR penalty regime. We have been aggressively pursuing OVDI opt-outs
Under IRS Form 1040, at the bottom of Schedule B, Part III, on Page 2, Question 7(a) states: “at any time during the previous year, did you have any interest in or signatory or other authority over a financial account
Suppose you have a foreign bank account holding more than $10,000. You may have inherited it, used it to hide money during a dispute with your spouse or business partner, or just done it on a whim. As you try
The Foreign Account Tax Compliance Act (FATCA) is about disclosure and transparency, but in part is to catch Americans trying to stash money overseas. Controversially, FATCA orders every foreign bank to track down its U.S. account holders, and then share
Comparison of Form 8938 and FBAR Requirements Many holders of foreign financial assets must file two disclosure forms this year or else risk draconian penalties. They are Form 8938, which is due with the tax return itself, and
This year, there is at least one new tax form for US taxpayers to be aware of: Form 8938: Statement of Foreign Financial Accounts. Since there are a number of sometimes obscure U.S. tax forms that U.S. taxpayers are required
The IRS has finally attempted to demystify its new Form 8938. Below are some Form 8938 FAQs: Basic Questions and Answers on Form 8938 1. What are the specified foreign financial assets that I need to report
In recent years, the IRS and US Treasury have stepped up their efforts toward tracking down delinquent tax payers and enforcing payment of overdue taxes. One of these initiatives has been labeled the “Foreign Account Tax Compliance Act”. FATCA is
The IRS and US Treasury have stepped up their efforts toward tracking down delinquent tax payers and enforcing payment of overdue taxes. One of these initiatives is the “Foreign Account Tax Compliance Act”. FATCA is part of the Hiring Incentives
I have frequently seen the following scenarios in working with clients to determine whether a offshore voluntary disclosure program filing (OVDP) is appropriate and how they should report foreign account. First, a parent or grandparent entrusts a younger generation family
US authorities have offered eleven financial institutions a settlement agreement in which the US government’s investigations in those financial institutions — for aiding tax evasion — and potential prosecution would be dropped. The eleven financial institutions are: 1. Credit Suisse
The Foreign Account Tax Compliance Act (FATCA) is about disclosure and transparency, but in part is to catch Americans trying to stash money overseas. Controversially, FATCA orders every foreign bank to track down its U.S. account holders, and then share
American Citizens Abroad (ACA) has written to IRS Commissioner Doug Shulman of the IRS to express the organization’s profound concern that he has not answered the Directive issued by National Taxpayer Advocate Nina Olson. In her report to Congress issued
The United States Senate has passed a provision in proposed legislation that would allow the State Department to deny, limit or revoke passports to citizens with “seriously” delinquent taxes. The passport provision is part of the Fight Offshore Tax Abuses
As anticipated, IRS Form 8938 Statement of Foreign Financial Assets is causing significant confusion among taxpayers attempting to complete these Forms for filing. Form 8938, Statement of Specified Foreign Financial Assets, is a new reporting form, which will be used to
The announcement by the IRS of the opening of the new Offshore Voluntary Disclosure Program (OVDP) on January 9, 2012 came as a surprise to most tax practitioners, especially since the 2011 OVDI just ended on September 9, 2011. However,
Yesterday the Internal Revenue Service opened its Offshore Voluntary Disclosure Program (OVDP) to encourage more taxpayers with assets in undeclared foreign bank accounts to come forward. While the OVDP was not expected by most tax lawyers and professionals, it may
The Internal Revenue Service today reopened the offshore voluntary disclosure program to help people hiding offshore accounts get current with their taxes. The IRS reopened the Offshore Voluntary Disclosure Program (OVDP) following continued strong interest from taxpayers and tax practitioners
Form 8938, Statement of Specified Foreign Financial Assets, is a new reporting form. Form 8938 will be used to report certain foreign financial assets as required as part of the Hiring Incentives to Restore Employment Act (HIRE Act), which was
In a fact sheet (IRS FS-2011-13) released last week, the IRS reminded U.S. citizens and dual citizens of the United States and foreign countries who live abroad about U.S. filing requirements, including Form TD F 90-22.1, Report of Foreign Bank
Earlier this month Credit Suisse Group AG, Switzerland’s second-biggest bank, told U.S. clients it is giving confidential client account data to the Swiss tax authorities, who will decide whether to disclose it to the Internal Revenue Service. The U.S. is
A federal grand jury in San Jose, California, last week indicted Ashvin Desai of San Jose on three counts of tax evasion, two counts of willfully aiding the preparation of materially false tax returns and three counts of failing to
Under the 2011 OVDI voluntary disclosure program, the penalties for failing to timely file Foreign Bank Account Reports, (FBAR’s) and the penalties for failure to file information returns (such as Controlled Foreign Corporation tax returns) were combined into a single
Although the OVDI program has expired, a U.S. taxpayer can still make a voluntary disclosure of foreign accounts pursuant to the IRS’s general voluntary disclosure policy. For over 50 years, the IRS has maintained a voluntary disclosure policy, under which
A Wisconsin neurosurgeon was re- indicted by a U.S. grand jury on new charges that he failed to declare an HSBC Holdings Plc (HSBA) account in India valued in 2009 at $8.7 million. Arvind Ahuja was indicted again by a
IRS Commissioner Shulman has invited persons with unreported foreign accounts to come forward and avail themselves of the IRS’s Voluntary Disclosure Practice. That practice is described in the Internal Revenue Manual 9.5.11.9. The Practice has a bearing upon whether the
As expected, the United States Internal Revenue Service (IRS) has disclosed that the recently-completed offshore voluntary offshore initiative (OVDI) has pushed the total number of voluntary disclosures up to 30,000 since 2009. The IRS customarily publicizes (and celebrates) such accomplishments.
Even though the deadline for the Internal Revenue Service’s 2011 Offshore Voluntary Disclosure Initiative has concluded last week, U.S. taxpayers with undisclosed offshore accounts still have the opportunity to come forward through the IRS’s traditional Voluntary Disclosure program. Like the
Last week, late on Friday afternoon, August 26, 2011, the IRS issued a statement indicating that the due date for filing 2011 Offshore Voluntary Disclosure Initiative (OVDI) requests has been extended until September 9, 2011, due to the potential impact
If the US dollar is as close as we have come to a global currency — accepted everywhere from Fifth Avenue boutiques to Coca-Cola stands in Afghanistan — why are some American citizens finding it hard to put their money