{"id":1253,"date":"2011-07-16T13:47:47","date_gmt":"2011-07-16T18:47:47","guid":{"rendered":"http:\/\/www.patellawoffices.com\/blog\/?p=498"},"modified":"2011-07-16T13:47:47","modified_gmt":"2011-07-16T18:47:47","slug":"in-addition-to-hsbc-credit-suisse-also-being-invsetigated-for-offshore-activities","status":"publish","type":"post","link":"https:\/\/patellawoffices.com\/blog\/planning-for-tax-minimization\/in-addition-to-hsbc-credit-suisse-also-being-invsetigated-for-offshore-activities\/","title":{"rendered":"In Addition to HSBC, Credit Suisse Also Being Investigated for Offshore Activities"},"content":{"rendered":"

On July 14, 2011, Credit Suisse received a letter notifying it that it is a target of\u00a0a Justice Department investigation.\u00a0\u00a0A target letter is significant.\u00a0 It likely means that a considerable level\u00a0of investigation has already been done and further criminal investigation is warranted.\u00a0 See Internal Revenue Manual, Part 9<\/a>.\u00a0Even before this stage a well-advised taxpayer\u00a0 proceeds with great caution.<\/p>\n

Credit Suisse is unlikely to be the only institution in the IRS\u2019s sights.\u00a0 It has been reported that U.S. authorities are conducting a broader industry inquiry.\u00a0 Credit Suisse points out that it has obligations under Swiss law, and those are not small.\u00a0 Credit Suisse says it will continue to cooperate with the U.S. authorities, subject to those rules.<\/p>\n

HSBC is also being scrutinized. On April 7, 2011, the U.S. District Court for the Northern District of\u00a0 California issued an order authorizing the Internal Revenue Service\u00a0 (\u201cIRS\u201d) to serve a \u201cJohn Doe<\/a>\u201d summons requesting information from\u00a0HSBC<\/a> regarding U.S. residents who may be using accounts at HSBC<\/a> in India to evade federal income taxes. If HSBC produces these records,\u00a0 which is likely, it may be too late for U.S. taxpayers with undisclosed\u00a0 HSBC accounts to take advantage of the IRS Voluntary Disclosure Program\u00a0 for offshore accounts. The IRS says there are 9,000 high net worth Indian US residents who\u00a0 maintain at least $100,000 in their bank accounts in HSBC India but only\u00a0 1,921 of them have disclosed details of their accounts.\u00a0 In a statement\u00a0 to a San Francisco court, senior IRS official Daniel Reeves said, \u201cThis\u00a0 indicates that thousands of US taxpayers of Indian origin who maintain\u00a0 more than $100,000 in accounts with HSBC, may have failed to disclose\u00a0 their HSBC India accounts to the United States Government.\u201d\u00a0 He went on\u00a0 to say, \u201cIt is also likely that those taxpayers may have failed to\u00a0 report income earned on those undisclosed accounts.\u201d<\/p>\n

The 2011 OVDI<\/a> is still pending and allowing\u00a0U.S. account holders\u00a0to come clean under the IRS amnesty policy.\u00a0 However, OVDI expires\u00a0August 31, 2011, although it\u2019s possible to ask the IRS for permission to extend the deadline for some materials until November 29, 2011.<\/p>\n

Patel Law Offices is a law firm dedicated to helping clients resolve\u00a0 complicated tax, criminal tax, and international tax problems. Our firm\u00a0 assists (and defends) clients and their advisors to legally disclose\u00a0 (and legitimize) foreign accounts.<\/p>\n","protected":false},"excerpt":{"rendered":"

On July 14, 2011, Credit Suisse received a letter notifying it that it is a target of\u00a0a Justice Department investigation.\u00a0\u00a0A target letter is significant.\u00a0 It likely means that a considerable level\u00a0of investigation has already been done and further criminal investigation is warranted.\u00a0 See Internal Revenue Manual, Part 9.\u00a0Even before this stage a well-advised taxpayer\u00a0 proceeds […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_daextam_enable_autolinks":"","_monsterinsights_skip_tracking":false,"_monsterinsights_sitenote_active":false,"_monsterinsights_sitenote_note":"","_monsterinsights_sitenote_category":0,"footnotes":""},"categories":[1],"tags":[19,20,23,24,52,27],"class_list":["post-1253","post","type-post","status-publish","format-standard","hentry","category-planning-for-tax-minimization","tag-amnesty","tag-asset-protection","tag-fbar","tag-foreign-account","tag-offshore","tag-voluntary-disclosure"],"_links":{"self":[{"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/posts\/1253","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/comments?post=1253"}],"version-history":[{"count":0,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/posts\/1253\/revisions"}],"wp:attachment":[{"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/media?parent=1253"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/categories?post=1253"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/patellawoffices.com\/blog\/wp-json\/wp\/v2\/tags?post=1253"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}