Potential ‘Treasure Trove’ of Information Pertaining To Offshore Voluntary Disclosure Program Released
Perhaps the advertising agency that developed the slogan, “If it’s Goya, it has to be good” got it wrong. Maybe what they really meant to say was, “If it’s FOIA, it has to be good.” To find out why, read on … Denis Brager, an esteemed tax attorney, has received more than 6,500 pages from […]
London Mayor Pushes Back Against the IRS For “Outrageous” Tax Assessment
London Mayor Boris Johnson is not taking the bait. He refuses to pay a tax assessment that the IRS claims he owes. The Mayor was born in New York and holds a U.S. passport as well as a British one. What brought this issue into the public spotlight? While visiting the U.S. last week to […]
How to Avoid Becoming The Next ‘Cooked Goose’ Gracing The IRS’s Offshore Tax Evasion Table This Thanksgiving
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 […]
THE NEW AMERICAN EXPAT: MORE COLLATERAL FATCA DAMAGE
As I reported in a previous article, the Department of Justice (DOJ) and the IRS instantly began to drool in anticipation when The Foreign Account Tax Compliance Act was passed in March of 2010. This gives them enforcement tools to make foreign countries and banking institutions play by our rules whether they like it or […]
Today’s Criminal Justice System: Does It Live Up To What The Founding Fathers Envisioned It To Be?
“A diligent prosecutor can convince a grand jury to indict a ham sandwich.” This quote by New York Court of Appeals Chief Judge Sol Wachtler was made even more famous in the Tom Wolfe novel The Bonfire of the Vanities. Apropos of nothing, Judge Wachtler also once referred to the death penalty as “the chicken […]
Government Expands Forfeiture Program
In 1984, George Orwell’s novel about a dystopian near-future society, Oceania was constantly at war with one of its geopolitical rivals. The grandfatherly yet sinister O’Brien later admitted that victory over Eurasia or Eastasia was not the war’s objective – the ongoing conflict was simply an excuse for the totalitarian government to intervene in peoples’ […]
Hong Kong and the United States Sign FATCA Agreement
On November 13, 2014, Hong Kong and the United States signed an inter-governmental agreement (IGA), which will require financial institutions in Hong Kong to comply with the US Foreign Account Tax Compliance Act (FATCA). FATCA provides the Internal Revenue Service (IRS) with the tools it needs (not a scalpel but a chainsaw) to obtain information on financial […]
Form 8938 and Offshore Real Estate Holdings
Owning a portfolio of offshore assets can be a headache thanks to the Foreign Account Tax Compliance Act (FATCA). FATCA requires both U.S. citizens and foreigners living in the U.S. to make extensive disclosures about overseas holdings on their tax returns or face stiff penalties. Foreign financial institutions also must report more detailed information on […]
Making Sense of the Model 2 FATCA Agreement Between Switzerland and the United States and What’s on the Horizon
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 […]