India Is Next Country on The Verge of Signing Onto FATCA
According to a Reuters article dated Wednesday, July 8, 2015, India and the United States are expected to sign a a tax information sharing agreement today, July 9, 2015, “under a new U.S. law meant to combat offshore tax dodging by Americans.” Excerpts from the article can be found below: “By signing the agreement, India hopes to garner Washington’s support for […]
Rand Paul Files Federal Lawsuit Against U.S. Treasury and IRS over IGA’s
Kentucky Senator and 2016 Republican Presidential hopeful Rand Paul recently announced that, in partnership with Republicans Overseas and five others, he would head to court to stop the vile Foreign Account Tax Compliance Act crackdown. At the risk of comparing the noted Republitarian/Libripublican figure with a certain single-cell cartoon villain, the effort may turn out […]
Two More Banks Reach NPAs with the Department of Justice
On June 19, 2015, the Department of Justice announced that two more banks reached resolutions under its Swiss Bank Program. Those banks are Bank Linth LLB AG (Bank Linth) and Bank Sparhafen Zurich AG (BSZ). According to the terms of the non-prosecution agreements, each bank has agreed to cooperate in any related criminal or civil proceedings, […]
[Don’t] Insert Money Here
It’s no coincidence that churches and banks are usually the two largest buildings in a community. “Filthy lucre,” as the King James so eloquently phrases it, has often reared its ugly head in Christian history. And if you think that the televangelist scandals of the 1980s were a recent development, think again. When Pope Urban […]
Two More Banks Reach Non Prosecution Agreements With U.S. Government
On Tuesday, June 9, 2015, the Department of Justice announced that two more banks had reached non prosecution agreements under the department’s Swiss Bank Program: Société Générale Private Banking (Suisse) SA (SGPB-Suisse) and Berner Kantonalbank AG (BEKB). According to the terms of the agreements, each bank has agreed “to cooperate in any related criminal or civil […]
Non-prosecution Agreements Galore: Two More Banks Ink NPAs with the Justice Department
On June 3, 2015, the Department of Justice announced that two banks, Rothschild Bank AG and Banca Credinvest SA, had reached resolutions under the department’s Swiss Bank Program. For those unfamiliar with the Swiss Bank Program, it “provides a path for Swiss banks to resolve potential criminal liabilities in the United States.” Banks contemplating such an agreement had until December […]
Four More Banks Reach Resolutions with U.S. Government for NPAs
On May 28, 2015, the Department of Justice announced the addition of four banks to its Swiss Bank Program. They are as follows: Société Générale Private Banking (Lugano-Svizzera) MediBank AG LBBW (Schweiz) AG Scobag Privatbank AG For those unfamiliar with the Department of Justice’s Swiss Bank Program, a slight digression may be in order. The Swiss […]
Consequences of IRS Tax Compliance for Offshore Residents
Since the time the IRS announced the revised Offshore Voluntary Disclosure Program, there has been a consistent restlessness among American expats. At the forefront of this change is the inclusion of the Streamlined Compliance Procedure Program, which is available to U.S. individual taxpayers residing in the United States as well as those who live abroad. […]
IRS Issues Updated Guidance for FBAR Penalties
The IRS recently issued a memorandum entitled, “Interim Guidance for Report of Foreign Bank and Financial Accounts (FBAR) Penalties.” As explicitly stated in the memorandum, its purpose is to improve the administration of the IRS’s FBAR compliance program. How so? By implementing new procedures. This guidance affects two specific IRMs: 4.26.16 and 4.26.17. For those […]
Addition of Pinter Bank Swells List of Foreign Banks To Which Enhanced OffShore Penalty Applies to Fifteen
Most U.S. taxpayers who enter the IRS Offshore Voluntary Disclosure Program must pay an offshore penalty equal to 27.5 percent of the highest year’s aggregate balance of their offshore accounts during an eight-year look-back period. On August 4, 2014, the IRS increased this penalty from 27.5% to 50% if the following conditions exist: (1) At the […]