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, […]
Bitcoin Accounts Not Required to be Reported on FBAR for 2013
Taxpayers with bitcoin accounts can breathe a small sigh of relief. According to the IRS, Bitcoin, also known as virtual currency, isn’t subject to FBAR reporting … at least for now. During a recent IRS webinar titled, “Reporting of Foreign Financial Accounts on the Electronic FBAR,” Rod Lundquist, Senior Program Analyst in IRS’s Small Business/Self Employed (SB/SE) division, stated […]
Getting to Know the Streamlined Domestic Offshore Procedures
U.S. taxpayers (or estates of individual U.S. taxpayers) seeking to use the Streamlined Domestic Offshore Procedures must satisfy the following requirements: (1) Fail to meet the non-residency requirement (for joint return filers, one or both spouses must fail to meet the non-residency requirement); (2) Have previously filed a U.S. tax return (if required) for each […]
The Good, the Bad, and the Ugly of the FATCA
If “FATCA” were a person and decided to enter a beauty pageant, it would be booed off the stage for being unsightly. If “FATCA” were a writer and decided to write a nonfiction book, it sure as heck wouldn’t be, “How to Win Friends and Influence People.” What is it about this petulant law that […]
OVDP or Streamlined: What Is My Best (Or Only) Option?
Recently, the IRS announced Streamlined Filing Compliance Procedures in order to encourage U.S. taxpayers to come into compliance with reporting their offshore financial accounts and assets. For eligible U.S. taxpayers residing outside the United States, all penalties are waived under the streamlined procedures. For eligible U.S. taxpayers residing within the United States, the only penalty […]
Tips For Surviving the Dreaded Eggshell Audit: Part II: A Hypothetical To Drive It All Home
This is a continuation of the blog entitled, “Tips for Surviving the Dreaded Eggshell Audit.” It focuses on spotting and solving some of the issues raised in an eggshell audit. This hypothetical comes from the creative genius of Jack Townsend and his book, “Tax Crimes.” You are the tax preparer for the Cashcows, owners of […]
Should I Stay Or Should I Go? Choosing Between Opting Out And Applying To The Streamlined Program Or Seeking Transitional Treatment
The tax community has been buzzing about an issue that has recently surfaced in the wake of the IRS’s overhaul of OVDP and the streamlined procedures. And that issue pertains to taxpayers who are currently in the OVDP and who want to “jump ship” for greener pastures – namely, the streamlined procedures. The issue is […]
Do You Need To Report On An FBAR & Form 8938 Your Offshore Gold, Cash & Notes?
As has become obvious, the IRS has stepped up its efforts to curb non-disclosure of offshore assets and underreported income by U.S. taxpayers. Tax compliance has risen to the top of the IRS agenda, and with widely publicized alerts from the IRS, claims of ignorance of the law aren’t likely to go very far. Contrary […]