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;
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
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
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
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
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
