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 […]
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 Do You Spell ‘Relief?’
This commercial always perplexed me as a child, because I was pretty sure that “relief” was not spelled as “r-o-l-a-i-d-s,” despite what the actors and TV announcers said. I finally took my concerns to my mother, because she always had all the answers. She assured me that I was right, and that the intentional misspelling […]
Bulgaria Becomes Latest Country To Sign On To FATCA
Bulgaria is the most recent country to ink a deal with the United States to implement FATCA, the Foreign Account Tax Compliance Act. Passed by Congress in 2010, the law is designed to stomp out offshore tax evasion, by targeting U.S. taxpayers with unreported offshore accounts. Under the law, foreign banks and financial institutions must […]
Switzerland’s Bank Secrecy To Come Tumbling Down Like Berlin Wall When Automatic Exchange of Information Treaty Goes Into Effect
Author Samuel Jaberg sat down to interview Jacques de Watteville, Switzerland’s State Secretary for International Financial Matters. Mr. de Watteville is the man in charge of implementing Switzerland’s new treaty on automatic exchange of information between tax authorities. Before we dive into the interview, some background information about how the automatic exchange of information works is useful. According to […]
HSBC Back In The Dog House Again
Last weekend, media reports cast an unflattering light on HSBC’s continued defiance to “straighten up and fly right” when it comes to assisting its foreign clients hide their accounts from taxing authorities in their home countries. The list of clients includes some you would least expect: global politicians, rock stars, arms dealers, and potential terrorists. […]
The Man (Or Woman) Without A Country
Over the last two years, the number of U.S. expatriations has skyrocketed. For 2013 alone, the number of Americans renouncing their citizenship has increased to 221%. As shocking as this statistic might sound, according to those in the “know,” it is grossly understated. This has inspired many to call the trend, “Ellis Island in reverse.” What has caused […]
International Data Exchange Service for FATCA Launched
On January 12, 2015, the IRS announced that it had opened a data exchange service for enrollment by financial institutions and countries to use for complying with a U.S. tax law. The purpose of the data exchange service is to facilitate the exchange of information between foreign financial institutions and host country tax authorities, on the one hand […]
National Taxpayer Advocate Lambasts IRS’s OVDP Programs and FBAR Penalties
Here ye, here ye! National Taxpayer Advocate, Nina Olson recently gave her annual report to Congress. And she didn’t mince words. She lambasted the IRS for relentlessly asserting onerous offshore penalties including its disproportionate treatment of non-willful taxpayers caught in the labyrinth of foreign asset reporting. Ms. Olson’s report asks the IRS to change its […]