IRS Unveils Updated List of Foreign Financial Institutions Or Facilitators That Trigger 50% Offshore Penalty In OVDP
The IRS recently updated the list of foreign financial institutions that trigger an enhanced penalty in OVDP. While the offshore penalty is generally 27.5% of the highest year’s aggregate balance during an eight year look-back period, to the extent that the taxpayer has an undisclosed foreign financial account with any one of the following banks at the time […]
Is the Justification for the United States’ System of Worldwide Taxation A Hoax (Part II)?
In Part I, I argued that the benefits rationale – in terms of the public benefits received by citizens – was an unpersuasive justification for the U.S.’s system of worldwide taxation. I continue my rant in Part II, examining the practical effects of worldwide taxation on non-resident U.S. citizens. Through a labyrinth of “credits, deductions, […]
Bank Leumi Enters Into Non-Prosecution Agreement With Department of Justice; Agrees To Release More Than 1,000 U.S. Account Holder Names
In order to avoid a fate similar to UBS, Bank Leumi recently admitted to engaging in some tax “hanky panky.” One of the largest banks in Israel, Leumi admitted that it helped U.S. taxpayers evade their taxes. How so? By helping these individuals to hide their income and assets in offshore accounts in Israel and […]
Is the Justification for the United States’ System of Worldwide Taxation A Hoax (Part I)?
The U.S. is one of the only countries left in the world that still taxes its citizens and residents on their worldwide income, regardless of where it is earned. In order to understand the debate, some background information about the different forms of worldwide taxation is necessary. There are two ways in which a nation may […]
Is FATCA Doing More Harm Than Good?
Few American laws have been as controversial as FATCA. FATCA stands for Foreign Account Tax Compliance Act, a law passed in 2010 to clamp down on the use of foreign bank accounts by U.S. taxpayers to hide money that is otherwise subject to taxation in the United States. FATCA is the U.S. government’s newest enforcement […]
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 […]
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 […]
The Spread of FATCA Envy Into The Northern And Western Hemispheres
South American countries have many reasons to be jealous of the United States. Most days, we have stable federal government. Our standard of living is mind-blowing for many people in impoverished countries. They view us as the land of opportunity. We argue about our health care system, but almost everyone gets the care they need. […]
Etre résident fiscal aux USA : les avantages & inconvénients
Pour ceux qui ne le sauraient pas, je parle français. Français était mon premier cycle majeur au collège et une langue que je suis passionné. A ce jour, je continue à pratiquer mon français en suivant des cours à l’Alliance Française de New York. Au cours des dernières semaines, je l’ai reçu plusieurs demandes de […]