A Message From Uncle Sam to Those With Foreign Assets: Don’t Forget Your U.S. Reporting Obligations
On April 10, 2015, the IRS issued a press release entitled, “IRS Reminds Those with Foreign Assets of U.S. Tax Obligations.” I’ve attached the relevant portions below: WASHINGTON — The Internal Revenue Service today reminded U.S. citizens and resident aliens, including those with dual citizenship who have lived or worked abroad during all or part […]
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 […]
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T-Minus Seven Days And Counting
Having trouble viewing this email?Click here WEBSITE FIRM OVERVIEW ATTORNEYS TAX SEMINARS TAX CHAT CONTACT April 9, 2015 The White Knight Chronicles OVDP And Double Counting: Oh The Agony! What is this phenomenon known as double counting? Why is it important? If you are shepherding clients through the OVDP program, or you are […]
How Do Taxes Influence Behavior?
Legislators have three needs in mind as they prepare tax laws- -the need to raise revenue, the need to be fair to taxpayers, and the need to influence taxpayers’ behavior. Below are three excise taxes that have affected the economy and consumers’ behaviors. All are direct taxes. A sin tax is used to discourage the […]
Swiss Bankers Skirt Jail Time in U.S. Tax Evasion Case Thanks To ‘Cooperation Agreement’
A combined fine of $225,000 and five years of unsupervised probation without jail time was handed down to two former bankers of Credit Suisse AG. Josef Dörig and Andreas Bachmann, both Swiss nationals, received the reduced sentence due to their cooperation with U.S. authorities. Their crime: helping U.S. citizens evade taxes. Just one year ago, […]
Peter Amrein: The Latest Swiss Banker to Have His Head Put On The Government’s Chopping Block
The Justice Department just recently announced its latest catch: Peter Amrein, a Swiss citizen and former asset manager at a Swiss asset management firm. Mr. Amrein pleaded guilty to one count of conspiracy to defraud the IRS, to evade federal income taxes, and to file false federal income tax returns. By way of his allocution during the […]
BSI SA is First Bank to Reach NPA Under Justice Department’s Swiss Bank Program
On March 30, 2015, the Department of Justice announced that BSI SA, one of the largest private banks in Switzerland, was the first bank to reach a resolution under the Department of Justice’s Swiss Bank Program. Below are excerpts from DOJ’s press release. I have removed the comments from agency officials in order to highlight the more salient points: […]
OVDP And Double Counting: Oh The Agony!
What is this phenomenon known as double counting? Why is it important? If you are shepherding clients through the OVDP program, or you are going through the program yourself, it is critical that you understand what it means and the governing principles behind it. Otherwise, you could be paying an offshore penalty that is exponentially […]
How Does the IRS Calculate Interest?
The IRS charges interest on late or unpaid taxes, regardless of cause. The period covered always begins with the original due date of the return, and ends with the receipt of payment by the IRS. You may incur interest expenses for late filing, or simply for making a mathematical error on your tax return. Generally, […]