Ms. Fournie Shows Fortitude in Fight Against the IRS
Undeclared accounts are the latest bane for Swiss banks, which are being pushed to the brink by U.S. authorities to release details of their U.S. accountholders who park assets there in order to avoid paying U.S. taxes. Many Swiss banks have what are referred to derogatively as, “recalcitrant accountholders.” Recalcitrant accountholders are those who, despite […]
BSI SA is First Bank to Reach NPA Under Justice Department’s Swiss Bank Program
On March 30, 2015, the Department of Justice announced that BSI SA, one of the largest private banks in Switzerland, was the first bank to reach a resolution under the Department of Justice’s Swiss Bank Program. Below are excerpts from DOJ’s press release. I have removed the comments from agency officials in order to highlight the more salient points: […]
OVDP And Double Counting: Oh The Agony!
What is this phenomenon known as double counting? Why is it important? If you are shepherding clients through the OVDP program, or you are going through the program yourself, it is critical that you understand what it means and the governing principles behind it. Otherwise, you could be paying an offshore penalty that is exponentially […]
What To Do Next After You’ve Been Pre-accepted Into OVDP
You’ve submitted your OVDP letter and attachments to the Voluntary Disclosure Coordinator and are reclining in your arm chair watching the “big game” while opening up the day’s mail. The upper left-hand corner of one of the envelopes in your pile is adorned with the IRS’s logo. You open it up. The letter is but […]
New FBAR Guidance Issued by IRS
Back on January 13, 2015, the IRS issued a bulletin entitled, “Options Available to Help Taxpayers With Offshore Interests,” designed to assist those who have failed to file timely FBARs. The bulletin is set up as a chart where a “Situation” is listed in the left-hand column and a “Compliance Option” is listed in the […]
Thinking of Hiding Money Abroad? Don’t be a “Dirty Dog!”
In a recent IR published on January 28, 2015, the IRS said that avoiding taxes by hiding money or assets in unreported offshore accounts remains on its “annual list of scams known as the ‘Dirty Dozen’ for the 2015 filing season.” The complete article can be accessed here, and is quoted below: WASHINGTON — The […]
National Taxpayer Advocate Lambasts IRS’s OVDP Programs and FBAR Penalties
Here ye, here ye! National Taxpayer Advocate, Nina Olson recently gave her annual report to Congress. And she didn’t mince words. She lambasted the IRS for relentlessly asserting onerous offshore penalties including its disproportionate treatment of non-willful taxpayers caught in the labyrinth of foreign asset reporting. Ms. Olson’s report asks the IRS to change its […]
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 […]
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 […]
Potential ‘Treasure Trove’ of Information Pertaining To Offshore Voluntary Disclosure Program Released
Perhaps the advertising agency that developed the slogan, “If it’s Goya, it has to be good” got it wrong. Maybe what they really meant to say was, “If it’s FOIA, it has to be good.” To find out why, read on … Denis Brager, an esteemed tax attorney, has received more than 6,500 pages from […]