Making Sense of the Model 2 FATCA Agreement Between Switzerland and the United States and What’s on the Horizon
As you may have heard by now, Switzerland is in the process of negotiating a Model 1 FATCA agreement with the United States. With the new agree- ment, U.S. accountholder information would be exchanged automatically with the U.S. government on a reciprocal basis.At present, Switzerland and the United States have a Model 2 IGA Agreement, which was approved by the Swiss Parliament on September 27, 2013.
For those who may be wondering, the FATCA agreement between Switzerland and the United States allows for such a change.In fact, according to the Swiss government‘s Federal Department ofce (FDF), “Questions and Answers” ontheautomaticexchangeofinformation, negotiationsonaModel1Agreement arealready underway.
DeBlis Law is a boutique litigation firm with a single mission: to provide outstanding legal services to individuals involved in crisis situations. Our firm specializes in civil tax controversies and in all aspects of criminal defense, including white-collar criminal defense and criminal tax defense.
We provide practical and sound advice to assist taxpayers with offshore financial assets come into compliance with their U.S. tax obligations.
Do You Need To Report On An FBAR & Form 8938 Your Offshore Gold, Cash & Notes?
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 to popular belief, not all foreign assets owned by U.S. taxpayers must be disclosed. This blog provides guidance to U.S. taxpayers who store gold and currency cash notes abroad in private vaults – a popular investment these days considering the uncertain global economy and the sharp declined in currency values.
Let’s begin with some basics. A U.S. person must file an FBAR if that person has a financial interest in or signature authority over any financial account(s) outside of the United States and the aggregate maximum value of the account(s) exceeds $ 10,000 at any time during the calendar year.
♦ Why did the cannibal tax accountant get disciplined? For buttering up her clients.
♦ Q: Why is a tax loophole like a good parking spot? A: As soon as you see one, it’s gone.
♦ Income tax is Uncle Sam’s version of “Truth or Consequences.”
“Foreign Asset Reporting: Navigating The Choppy Financial Seas”
Be one of the first to get a copy of my new ebook. “Click here.”
Anatomy of a Civil Tax Controversy
Below is a brief, thumbnail sketch of the steps involved in challenging a tax deficiency, beginning with receipt of the “30-day letter” and ending with the taxpayer filing a petition with the
tax court (if matters get that far). In future blogs, I’ll expound on each individual step.
Step one: The IRS conducts a tax audit. A tax audit is an examination of your income and expenses to ensure that you correctly reported your tax liability. All types of tax returns are subject to audit, including income, business, estate, and gift tax returns.
SB/SE Issues Memo Outlining Changes to the Limitations Period for Cases Going to and Coming from IRS Appeals
This article was co-authored by Randall Brody, EA of Tax Samaritan. I wish to acknowledge his keen insight and invaluable contributions to this article.
Picture this. You receive a notice of determination from the IRS informing you that you owe more tax than you reported on your tax return. As is usually the case, the IRS issues a 30-day letter, advising you that you have 30 days to request Appeals consideration of the case.