T-Minus Two Days And Counting
Taxpayers who are considering applying to the OVDP should be mindful of a certain upcoming deadline: August 3, 2014. Willful non-disclosers who do not apply to the OVDP by August 3, 2014 and who have an offshore bank account with a foreign financial institution which has been publicly identified as being under investigation, or is […]
What Should I Do If My Non-Consenting Swiss Bank Account Becomes The Target of an IRS Group Request?
Suppose that you have an undisclosed offshore account with XYZ Bank, a Swiss bank. You received a declaration of consent from XYZ Bank requesting your consent to disclose your account information to the IRS directly. You refused. Because you did not consent, your account became subject to aggregate reporting by XYZ Bank. Pursuant to the Swiss-U.S. FATCA Agreement, Swiss […]
What Should I Do If I Have Received a “Declaration of Consent” Form From My Swiss Bank?
Picture this. You have an offshore account with a Swiss Bank that, for whatever reason, you haven’t gotten around to reporting on your U.S. tax return or on a FBAR. One morning, as you are sipping your coffee and checking your email inbox, you come across an ominous email from your Swiss Bank. The subject […]
Show Me The Money! Is The Source of OVDP Revenue Coming From Taxes Or Excessive Offshore Penalties?
On June 18, 2014, IRS Commissioner John Koskinen disclosed that the 2009, 2011, and ongoing 2012 offshore voluntary disclosure programs have resulted in more than 45,000 disclosures and the collection of about $6.5 billion in taxes, interest, and penalties. On its face, the OVDIs appear to be bringing into the government’s coiffures an average of […]
How Harry Potter Can Help You Navigate The Labyrinth of Overlapping Rules Within OVDP
Nary a day goes by that I don’t talk to a client who is confused about one or more aspects of the OVDP program. Most of the time, it’s not the client’s fault. Usually, the confusion lies in the fact that the rules themselves are like a tangled web or labyrinth on the scale of […]
Are the Streamlined Procedures My Best Option?
The IRS recently overhauled its offshore voluntary disclosure program, making changes to the 2012 Offshore Voluntary Disclosure Program (OVDP) and expanding the 2012 Streamlined Filing Compliance Procedures. This blog focuses on the changes made to the streamlined filing compliance procedures and some of the factors that should be considered when evaluating your options. Now more than […]
HSBC India Client Convicted of Hiding Offshore Accounts From IRS
Ashvin Desai, an offshore account taxpayer, was previously convicted for concealing more than $ 8 million in foreign bank accounts. Last week, he was sentenced by U.S. District Judge Edward J. Davila to six months in prison and six months and one day of home confinement. Desai was a medical device manufacturer who failed to […]
The Modified OVDP And Streamlined Procedures: A Library of Links to IRS Documents & Forms
The IRS recently made changes to the 2012 Offshore Voluntary Disclosure Program (OVDP) and expanded the 2012 Streamlined Filing Compliance Procedures. The changes are as follows: (1) OVDP • Taxpayers must submit all account statements and pay the offshore penalty at the time application to OVDP is made. • The offshore penalty will increase from 27.5% […]
The Lighter Side of Tax (Part II)
These “tax jokes” are the creative genius of The Unknown Tax Comic, who writes exclusively for TaxConnections. For more hilarious tax jokes, check out the Unknown Tax Comic’s blog at TaxConnections. ♦ Did you ever notice that when you put the words “The” and IRS” together, it spells “THEIRS” – Unknown ♦ A tax accountant […]
A Clash of Mammoth Proportions: In One Corner, Switzerland’s Tradition of Bank Secrecy And In The Other, FATCA
While the Swiss banking system’s reputation for hiding numbered bank accounts under a cloak of anonymity was once considered sacrosanct, the seal was broken on its banking secrecy back in 2013 when it signed an international agreement with the OECD (Organization for Economic Cooperation and Development) to fight tax evasion. Since then, other international agreements, […]