Offshore Voluntary Disclosure Program

State Offshore Voluntary Disclosure – Because One Tax-osaurus Rex Wasn’t Enough
Listen The Tax-osaurus Rex, or the fearsome offshore voluntary disclosure programs, has made thousands of taxpayers panic since it smashed through the scene a few years ago. While some chose to run and probably ended up torn to parts by vicious raptors (collectors), others are trying to survive by disclosing their foreign accounts and making …
Penny Wise And Pound Foolish
Listen Philip Wrigley had a problem. As the notoriously parsimonious owner of the Chicago Cubs in the 1970s, Mr. Wrigley did not want to spend big money to attract top players. But, as the savvy owner of a successful confectionary business, he also knew that no one would buy tickets to see a perennially second-division …
Two More Banks Reach NPAs with the Department of Justice
Listen 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 …
Four More Banks Reach Resolutions with U.S. Government for NPAs
Listen 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 …
Addition of Pinter Bank Swells List of Foreign Banks To Which Enhanced OffShore Penalty Applies to Fifteen
Listen 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 …
From Convicted Felon to Government-Made Millionaire: The Man Who Ended the Tradition of Bank Secrecy and Got Rich in the Process
Listen Meet Bradley Birkenfield. Mr. Birkenfield, a former Swiss banker, was released from federal prison three years ago after serving 2½ years for helping wealthy American clients hide millions of dollars from the U.S. government. Five weeks after his release from prison, Birkenfield was sitting on his couch wallowing in his misery, recognizing that he was unemployable as a private banker anywhere. But little …
OVDP & Double Counting: Traps for the Unwary
Listen Accounting for “double counting” is not child’s play. Your tax attorney will need the following information in order to complete his or her review of your double counting issue. These steps must be repeated for every year in which you believe that there is a double counting issue. For each transfer, you should provide the …
OVDP And Double Counting: Oh The Agony! – Part II
Listen This is a continuation of Part I. This hypothetical pertains to a taxpayer who has applied to OVDP and who has transferred assets from one foreign account, which was recently closed, to another during the disclosure period. This is a simple example, yet it illustrates some of the common mistakes that are associated with …