July 2014

What Should I Do If My Non-Consenting Swiss Bank Account Becomes The Target of an IRS Group Request?
Listen 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, …
FedEx Faces Federal Indictment Over Alleged Role In Conspiring To Traffic Controlled Substances & Prescription Drugs
Listen A federal grand jury in San Francisco Thursday indicted FedEx Corporation, FedEx Express, Inc. and FedEx Corporate Services Inc. with conspiracies to traffic in controlled substances and misbranded prescription drugs for its role in distributing controlled substances and prescription drugs for illegal Internet pharmacies. According to the indictment, beginning in 1998, Internet pharmacies began …
Show Me The Money! Is The Source of OVDP Revenue Coming From Taxes Or Excessive Offshore Penalties?
Listen 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 …
Are the Streamlined Procedures My Best Option?
Listen 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 …
HSBC India Client Convicted of Hiding Offshore Accounts From IRS
Listen 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 …
The Modified OVDP And Streamlined Procedures: A Library of Links to IRS Documents & Forms
Listen 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 …