Search results for OVDP

Think You Can Hide From The IRS? Target Orange County, California

The IRS is using its extensive Big Data resources to pin-point their investigations to the wealthiest areas in Orange County, California. The idea being that anyone who is selected for investigation in these areas will result in a higher tax liability than those who live in less affluent areas. The government is looking for non-filers, persons engaged in on-line and virtual currency transactions, businesses cheating or delinquent on employment taxes and individuals with undisclosed foreign bank accounts.

Non-Filers

When a taxpayer does not file and the IRS has information statements indicating a filing requirement, the IRS uses the data to file a return on behalf of the taxpayer if there is a projected balance owed. In 2012, the IRS used information statements to file 803,000 Read More

Written by | Posted in FATCA • FBAR • IRS • OVDP • Virtual Currency

Think You Can Hide From The IRS? Target San Francisco Bay Area, California

The IRS is using its extensive Big Data resources to pin-point their investigations to the wealthiest areas in the San Francisco Bay Area and Silicon Valley. The idea being that anyone who is selected for investigation in these areas will result in a higher tax liability than those who live in less affluent areas. The government is looking for non-filers, persons engaged in on-line and virtual currency transactions, businesses cheating or delinquent on employment taxes and individuals with undisclosed foreign bank accounts.

Non-Filers

When a taxpayer does not file and the IRS has information statements indicating a filing requirement, the IRS uses the data to file a return on behalf of the taxpayer if there is a projected balance owed. In 2012, the IRS used information statements to file 803,000 returns Read More

Written by | Posted in FATCA • FBAR • Income Tax • Individual • IRS • Tax Fraud/Evasion/Crimes

U.S. Cracks Israeli Bank Leumi – Bank Admits to Assisting U.S. Taxpayers in Hiding Assets in Offshore Bank Accounts

Americans with Israeli bank or other financial accounts could face a tough tax season in 2015 if they do not come forward and disclose their assets to the IRS. Israeli banks have come under increased scrutiny by the IRS in regards to disclosing the accounts of their American clients. In particular, three Israeli banks- Bank Hapoalim, Bank Leumi and Mizrahi Tefahot- have been under investigation by the Department of Justice.

The first Israeli bank to now bow to the United States is Bank Leumi. A deferred prosecution agreement between the Bank Leumi Group and the U.S. Department of Justice was filed today in the Central District of California that defers prosecution on a criminal information charging the bank with conspiracy to aid and assist in the preparation and presentation of false tax returns and other documents to the Internal Revenue Service. This is the same type Read More

Written by | Posted in FATCA • FBAR • OVDP • Tax Fraud/Evasion/Crimes

Don’t Believe The Seven Deadly Myths Of FATCA Non-Enforcement

This May Be Your One Last Opportunity to Avoid Criminal Prosecution and Increased Civil Penalties!

Since July 1, 2014, the most feared U.S. legislation regarding international tax enforcement – Foreign Account Tax Compliance Act (“FATCA”) – is being implemented by most banks around the world. As part of this compliance, foreign banks from around the world are sending letters to account holders that they believe have, or had, a U.S. tax nexus (or other U.S. connection) requesting information to determine whether such account holders have disclosed their foreign bank accounts to the IRS. The letters from foreign banks generally require an account holder to disclose whether the account has been declared to the IRS through the filing of a Report of Foreign Bank and Financial Accounts (commonly known as Read More

Written by | Posted in FATCA • FBAR • OVDP

2015: A New Year And A New Era – Number of FATCA Compliant Countries Continues To Increase

Under the Foreign Account Tax Compliance Act (“FATCA”), foreign banks, insurers and investment funds must send the Internal Revenue Service (IRS) information about Americans’ and United States permanent residents’ offshore accounts worth more than $50,000.  Institutions that fail to comply could effectively be frozen out of U.S. markets.  As of this blog posting, the U.S. has entered into Intergovernmental Agreements (“IGA’s”) with 48 countries for the implementation of FATCA.

The 48 countries with IGA’s already in place are:

 

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Written by | Posted in FATCA

London Mayor Refuses To Pay U.S. Tax Bill

London Mayor Boris Johnson is being pursued by U.S. tax officials while his former New York counterpart Michael Bloomberg was given an honorary knighthood by Queen Elizabeth last month.

Beware As The U.S. Tax Net Closes On Thousands Of U.S. Citizens Living Abroad.

The Conservative mayor of London – who was born in New York and holds an American passport – just revealed he is being pursued by the U.S. authorities for an unpaid tax demand. The demand reportedly relates to his first home in the UK, which he said was not subject to capital gains tax in England. According to U.S. tax law all citizens are required to file a tax return and pay U.S. taxes, even those with dual citizenship and Read More

Written by | Posted in Income Tax • International • IRS

Not On My Watch

When European financial giant Credit Suisse AG pleaded guilty to assisting U.S. taxpayers evade federal income tax, there was a great deal of swagger at the Justice Department. Former Attorney General Eric Holder, in classic Clint Eastwood style, boldly proclaimed that “no financial institution. . .is above the law,” and that any other bank which dared engage in such “brazen misconduct” would be “prosecut[ed] to the fullest extent possible.” Not to be outdone, Deputy AG James Cole warned investors that, if government investigators began asking questions, “[o]nly through full cooperation will you avoid the most severe sanctions.”

Tough words, indeed. But what is behind the Justice Department’s bravado, and what options do you have if you get a not-so-friendly phone call or if authorities suddenly Read More

Written by | Posted in FATCA • FBAR • IRS • OVDP

How To Avoid Becoming The Next “Cooked Goose” Gracing The IRS’s Offshore Tax Evasion Table This Thanksgiving – Part II

II. Essential Elements of Tax Crimes

a. Willfulness

One small word is all that distinguishes a civil tax matter from a criminal tax matter. That pestilent word is called “willfulness.” It is the cornerstone to any criminal tax matter.

In the criminal setting, the government carries the heavy burden of proving – beyond a reasonable doubt – that the taxpayer acted willfully. Willfulness is defined as an “intentional violation of a known legal duty.”

i. Proving Willfulness For Purposes of the Crime of Failure to File a FBAR Read More

Written by | Posted in FATCA • OVDP • Tax Fraud/Evasion/Crimes

How To Avoid Becoming The Next “Cooked Goose” Gracing The IRS’s Offshore Tax Evasion Table This Thanksgiving – Part I

If your name was mentioned in the same sentence as Raoul Weil, Carl Zwerner, or Ty Warner, you can rest assured that you haven’t been nominated for an academy award or a Pulitzer Prize. Nor did you win the Publisher’s Clearinghouse Award. Instead, you’d have joined a disgraced group of taxpayers who have had the misfortune of being targeted by the U.S. government in their crusade to stamp out offshore tax evasion.

In stark comparison is John Doe, a conflicted taxpayer who recently entered the Offshore Voluntary Disclosure Program (OVDP). Neighbors and friends who run into John are a captive audience for him as he wallows in his self-pity. John regrets the decision to enter OVDP and tells his tale of woe to anyone who will listen: “I don’t know what I’m doing in this program. I know 500 people with foreign accounts like mine, and they’re not coming Read More

Written by | Posted in FATCA • OVDP • Tax Fraud/Evasion/Crimes

The Hunt For Snowbirds Is On – A Summary of The IRS’s FAQ On Amnesty Programs For Non-Compliant Taxpayers

Since announcing its amnesty programs for non-compliant taxpayers, the IRS has received over 45,000 applications from those who wanted to fulfil tax filing obligations. According to the IRS, this meant $6.5 billion in taxes, interest, and penalties. With FATCA and global bank transparency also in action, the IRS is expecting even more mula from the pockets of expats with foreign accounts.

Why are so many U.S. taxpayers willingly complying? Because the new streamlined program is broader than it was back in 2012. The revamped version even eliminates the necessary risk questionnaire and the rule that taxpayers have $1,500 at most of unpaid taxes per year. Even “better” is the fact that taxpayers can provide a non-willful certification to justify their failure to report their foreign assets in the past. If a taxpayer is found eligible: Read More

Written by | Posted in FBAR • Individual • International • IRS

What Offshore Delinquent U.S. Individual Filers Need To Know! – Part 4

Is acceptance of a streamlined application automatic for those residing in Canada?

Answer

The primary criteria for acceptance into the Streamlined Foreign Offshore Procedure (“SFOP”) is that the reason for the non-compliance was due to non-willful conduct and that you meet a non-residency test.

Non-willful conduct requires you to certify on IRS Form 14653. Non-willful conduct is conduct that is due to negligence, inadvertence, or mistake or conduct that is the result of a good faith misunderstanding of the requirements of the law.

The non-residency requirement is generally met if in any one of the 3 past due years, you Read More

Written by | Posted in Canada • FBAR • OVDP
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