Deutsche Bank Becomes Latest Bank to Cooperate With DOJ In Its Swiss Tax Evasion Probe
A day doesn’t go by without a new development regarding FATCA. Friday, October 10, 2014 was no exception. That day, in an article entitled, “Deutsche Bank to Aid U.S. Justice Department in Swiss Tax Evasion Probe,” The Wall Street Journal reported that Deutsche Bank was cooperating with the U.S. Justice Department to turn over the […]
Virtual Currencies: The Modern-day Equivalent of Your Father’s Offshore Bank Account?
In this high tech era of GPS trackers and unmanned drones, new concerns are emerging over the erosion of personal privacy space. A new federal law compels the Federal Aviation Administration to allow drones to be used for all sorts of commercial endeavors – from selling real estate to monitoring oil spills. That same law […]
Why Are Banks Saying Sayonara to U.S. Expats?
Fidelity Investments appears to be the latest unintended consequence of the United States’ stepped-up efforts to collect taxes from its citizens and residents regardless of where they live and earn their money. Last July, Fidelity decided to bar its U.S. clients living abroad from buying or trading its mutual funds. Ironically, even though it has […]
From Chipolatas to Weisswurst With A Side of Cherry Tomatoes: A Recipe For Whipping Up The Streamlined Offshore Penalty In Three Easy Steps
Before reading this blog, I make the following disclaimer. If it is getting close to lunch time and you can hear your stomach growling, you might want to put off reading this until after lunch. Readers who disregard this warning are doing so at their own risk. Calculating the offshore penalty within the Streamlined Domestic […]
Changes to the Streamlined Procedures in the Offing?
In an article that appeared on Tax Connections last week entitled, “Changes To the Streamlined Version of OVDP To Be Announced Soon?,” author Ronald Marini, Esq. foreshadows several changes to the streamlined version of the Offshore Voluntary Disclosure Program. For those cynics who said, “I knew it! It was just a matter of time before […]
“I’ve Been a Bad, Bad Taxpayer” – A Look at the Certification for Non-Willfulness in Streamlined Procedures
Growing up, your mother probably resorted to sweetness to get you to confess to the broken window she knows your baseball caused. It was easier for you to take the blame then because her words were comforting and put your mind at ease. Well, the IRS has resorted to something quite similar. On June 18, […]
Getting It Right on FATCA
In the words of the famous fictional character, Homer Simpson, “D’oh!” I made a mistake. And I’m not going to waste any time in fixing it. This isn’t the first time and it likely won’t be the last. While no one likes to make mistakes, I’ve learned from my experience as an improviser and a […]
Should I Stay Or Should I Go? Fee To Renounce Citizenship Has Dramatically Increased By 422%
Thinking about renouncing your citizenship? After reading this blog, you may want to think twice. Over the last two years, the number of U.S. expatriations has risen dramatically. While it might not be Ellis Island in reverse, it’s damn near close. What has caused people to resort to an option as drastic as renouncing their […]
IRS Unveils More User Friendly Forms For Streamlined Procedures
The IRS has just recently updated the Streamlined Procedure forms for both its “foreign” and “domestic” procedures. All of the information can now be typed directly into the fields. Even the statement of facts can be cut and pasted directly onto the Form. This should help simplify the process. The forms can be found by clicking on […]
How Likely Is The IRS To Audit Me If I Quietly Disclose My Previously Unreported Offshore Account Pursuant To An Amended Return And A Delinquent FBAR?
It is the most dreaded letter a taxpayer can receive. Dear Taxpayer, Some of the information that you provided to us does not agree with the information we received from other sources. — The Internal Revenue Service You’ve just joined an elite club, one whose initiation ritual is an IRS audit. Unfortunately, you can’t refuse […]