Somebody Got Pinched
Well, so much for honor among thieves, at least as the U.S. government defines the t-word. Swiss bankers felt they had no choice but to violate the two greatest things in life. But this time, the allegations were quite a bit more serious than selling cigarettes without a retail permit, and there was no grinning […]
Tax Planning On The Edge – Ride Or Die In The International Tax Arena
Red Card
Ever since the United States hosted the World Cup Finals in 1994, soccer has struggled to find a place in the overwhelmingly crowded American sports landscape. So, if you subscribe to the theory that there’s no such thing as bad publicity, the recently-unsealed indictments in New York may be the best thing to happen since […]
Non-prosecution Agreements Galore: Two More Banks Ink NPAs with the Justice Department
On June 3, 2015, the Department of Justice announced that two banks, Rothschild Bank AG and Banca Credinvest SA, had reached resolutions under the department’s Swiss Bank Program. For those unfamiliar with the Swiss Bank Program, it “provides a path for Swiss banks to resolve potential criminal liabilities in the United States.” Banks contemplating such an agreement had until December […]
Game Changer
With all the brouhaha surrounding the Patriots’ win in Super Bowl XLIX this past February, New England’s Bill Belichick effectively cemented his legacy as a brilliant coach, shrewd general manager and impenitent cheater. According to the official deflate-gate report, the team intentionally underinflated game balls in its victory over the Indianapolis Colts in the AFC […]
Four More Banks Reach Resolutions with U.S. Government for NPAs
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 Swiss […]
Consequences of IRS Tax Compliance for Offshore Residents
Since the time the IRS announced the revised Offshore Voluntary Disclosure Program, there has been a consistent restlessness among American expats. At the forefront of this change is the inclusion of the Streamlined Compliance Procedure Program, which is available to U.S. individual taxpayers residing in the United States as well as those who live abroad. […]
IRS Issues Updated Guidance for FBAR Penalties
The IRS recently issued a memorandum entitled, “Interim Guidance for Report of Foreign Bank and Financial Accounts (FBAR) Penalties.” As explicitly stated in the memorandum, its purpose is to improve the administration of the IRS’s FBAR compliance program. How so? By implementing new procedures. This guidance affects two specific IRMs: 4.26.16 and 4.26.17. For those […]
What If …
Having trouble viewing this email?Click here WEBSITE FIRM OVERVIEW ATTORNEYS TAX SEMINARS TAX CHAT CONTACT May 19, 2015 The White Knight Chronicles What If … What if Adam and Eve had admitted that they ate from the Tree of Knowledge of Good and Evil, instead of pointing the finger at anyone else, and […]
Addition of Pinter Bank Swells List of Foreign Banks To Which Enhanced OffShore Penalty Applies to Fifteen
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 the […]