Search results for OVDP

I’m Sorry…

In 1811, President James Madison started the Federal Conscience Fund, which allows guilt-ridden Americans to surreptitiously atone for their financial sins. Over the years, generous benefactors have achieved various levels of catharsis. Typical donors range from guilty individuals, such as a Massachusetts woman who mailed in nine cents, because she re-used three postage stamps, to a government contractor haunted by the ghosts of Christmas past who sent in some $400,000.

Predictably, many people send in offerings to clear their consciences “with the IRS and with God.” One anonymous woman generously offered a few hand-made quilts to settle her tax debt. But perhaps the best of all is a man who emptied his conscience by writing, “I cheated on my income taxes and haven’t been able to sleep. So, I enclose a cashier’s Read More

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

The Choice: Amnesty Or Quiet Disclosure For Foreign Bank Accounts: Criminal Tax Evasion, Negligence, Or Ignorance?

Preliminary Introduction For TaxConnections Global Internet Tax Summit, September 21-25, 2015

The most recent IRS push to close “the Gap” between collected U.S. tax revenue and the total tax revenue which should be reported by U.S. citizens and alien residents of the United States has focused on offshore income concealed in foreign or offshore accounts.

U.S. citizens are liable for U.S. taxation on all income realized globally, regardless of the foreign jurisdiction in which their funds are deposited in foreign accounts.  U.S. citizens are not only liable for U.S. tax on such foreign sources of income, they are required to report all funds in excess of $10,000.00 on deposit in foreign accounts over which they have “signature authority” even if they only have a nominal “financial interest” in the Read More

Written by | Posted in FATCA • FBAR • Individual • International • Internet Tax Summit - 2015 • OVDP • Tax Controversy • Tax Fraud/Evasion/Crimes • TaxConnections

Two More Banks Reach NPAs With The Department of Justice

On June 19, 2015, the Department of Justice announced that two more banks reached resolutions under its Swiss Bank Program. Those banks are Bank Linth LLB AG (Bank Linth) and Bank Sparhafen Zurich AG (BSZ).

According to the terms of the non-prosecution agreements, each bank has agreed to cooperate in any related criminal or civil proceedings, demonstrate that it is implementing controls to stop misconduct involving unreported U.S. accounts, and pay penalties. In exchange, DOJ has agreed not to prosecute these banks for tax-related crimes.

In addition, each bank is encouraging its U.S. accountholders to come into compliance Read More

Written by | Posted in OVDP

4 More Banks Reach Resolutions With U.S. Government For NPAs

On May 28, 2015, the Department of Justice announced the addition of four banks to its Swiss Bank Program. They are as follows:

• Société Générale Private Banking (Lugano-Svizzera)

• MediBank AG

• LBBW (Schweiz) AG

• Scobag Privatbank AG

For those unfamiliar with the Department of Justice’s Swiss Bank Program, a slight digression may be in order. The Swiss Bank Program was unveiled on August 29, 2013. Read More

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

Consequences of Internal Renenue Service Tax Compliance for Offshore Residents

Since the time the IRS announced the revised Offshore Voluntary Disclosure Program, there has been a consistent restlessness among American expats. At the forefront of this change is the inclusion of the Streamlined Compliance Procedure Program, which is available to U.S. individual taxpayers residing in the United States as well as those who live abroad.

The Streamlined Foreign procedures cater to those U.S. citizens or lawful permanent residents – i.e., expats – who satisfy the non-residency requirement. The non-residency requirement has two strands. First, the taxpayer must not have a U.S. abode. And second, the taxpayer must have lived outside of the U.S. for at least 330 full days in at least one (or more) of the most recent three years for which the U.S. tax return due date (or properly Read More

Written by | Posted in OVDP

Pinter Bank Swells List of Foreign Banks To Which Enhanced OffShore Penalty Applies

Most U.S. taxpayers who enter the IRS Offshore Voluntary Disclosure Program must pay an offshore penalty equal to 27.5 percent of the highest year’s aggregate balance of their offshore accounts during an eight-year look-back period. On August 4, 2014, the IRS increased this penalty from 27.5% to 50% if the following conditions exist:

(1) At the time the taxpayer initiated their disclosure, one or more of the following applies:

a. A foreign financial institution at which the taxpayer had an account had been publicly identified as being under investigation, the recipient of a John Doe Summons or is cooperating with a government investigation, including the execution of a deferred prosecution agreement or non-prosecution agreement; or Read More

Written by | Posted in OVDP

Ms. Fournie Shows Fortitude in Fight Against the IRS

Undeclared accounts are the latest bane for Swiss banks, which are being pushed to the brink by U.S. authorities to release details of their U.S. accountholders who park assets there in order to avoid paying U.S. taxes. Many Swiss banks have what are referred to derogatively as, “recalcitrant accountholders.” Recalcitrant accountholders are those who, despite the bank’s prodding, refuse to report their foreign accounts to the IRS. Very simply, this group is what stands in the way of a “cooperating” bank opening up the kimono – i.e., by sending the U.S. government the records of its U.S. accountholders – and the pot of gold at the end of the rainbow: immunity from prosecution and overbearing penalties. Soon, the Foreign Account Tax Compliance Act (FATCA) will change all that. If the United States’ demands to expose tax-evaders are fulfilled, all data on these recalcitrant Read More

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

Ty Warner, Beanie Babies Creator, Convicted For Not Disclosing Foreign Bank Accounts

It’s been about 20 years since the U.S. suddenly fell in love with the adorable 5-inch Beanie Baby dolls created by Ty Warner. But in October 2013 billionaire Ty Warner broke down crying in U.S. District Court as he pleaded guilty to one count of tax evasion for hiding $25 million in income in secret Swiss bank accounts.

The Rise And Fall Of Beanie Babies

Ty Warner wasn’t afraid to take risks. Beanie Babies first appeared in 1993, triggering a craze for the plush toys fashioned into bears and other animals. He ignored the naysayers after Beanie Babies flopped during their initial debut, and pressed forward with a product he believed in more than anyone else. One reason why the toys easily supplanted other fads such as Ninja Turtles and Cabbage Patch dolls was partly because of Mr. Warner’s Read More

Written by | Posted in FBAR • Individual

IRS Agents To Hunt Tax Dodgers Overseas

On a recent airplane trip from the Bay Area to Southern California, I sat beside a distinguished-looking elderly man. I initiated a conversation with him and found out he was a former judge now living in Mexico. We talked about everything, including taxation.

The former judge admitted that he was an American citizen and he and some of his friends have problems sleeping because of Foreign Account Tax Compliance Act (FATCA). So, I asked him what about Foreign Bank Account Reporting (FBAR), as that was more serious than FATCA. But he had never heard about it. I wondered how many people are like the former judge and his friends who can’t sleep at night because of FATCA and who never heard of FBAR. Read More

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

IRS Extended A Sweetheart Deal On Valentine’s Day To U.S. Taxpayers With Undisclosed Foreign Bank Accounts

On June 18, 2014, the IRS announced major changes in the 2012 offshore account compliance programs, providing new options to help taxpayers residing in the United States and overseas. The changes are anticipated to provide thousands of people a new avenue to come back into compliance with their tax obligations and would largely waive these penalties if taxpayers come forward and show that they didn’t hide the money on purpose.

Separate from United States income tax returns, many U.S. persons are required to file with the U.S. Treasury a return commonly known as an “FBAR” (or Report of Foreign Bank and Financial Accounts; known as FinCEN Form 114), listing all non-US bank and financial accounts. These forms are required if on any day of any calendar year an Read More

Written by | Posted in FBAR • IRS • OVDP • Tax Fraud/Evasion/Crimes
« Older Entries   Recent Entries »