Category Archives: 2012 OVDP

WHY NOW IS A PROPITIOUS TIME FOR THOSE WITH UNREPORTED OFFSHORE ACCOUNTS TO MAKE A VOLUNTARY DISCLOSURE?

One oddity about the Offshore Voluntary Disclosure Program (OVDP) is that the FBAR years included in the criminal and reduced penalty partial-amnesty period are geared to one’s income tax filings.  (IRS OVDP FAQ 9) Thus, once a correct income tax … Continue reading

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IRS AND DOJ BANK DISCLOSURE SNOWBALL KEEPS ROLLING DOWNHILL BECOMING LARGER WITH EACH TURN

The Department of Justice (DOJ) website correctly states that the division’s investigations encompass “an ever-widening circle of banks.”  Recent events prove this statement true. Investigations are under-way on 14 of the largest banks in Switzerland, and banks in India, Israel … Continue reading

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LATEST DOJ ATTACK ON OFFSHORE ACCOUNTS: JOHN DOE SUMMONSES ISSUED TO U.S. CORRESPONDENT BANKS OF OFFSHORE BANKS

By now, I’m sure anyone owning an undisclosed offshore bank account has become familiar with the term, “John Doe Summons.”  After all, following the IRS issuing a John Doe Summons to UBS, it announced the 2009 OVDP, and about 15,000 … Continue reading

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ACCIDENTAL U.S. TAX RESIDENTS CAUGHT IN OFFSHORE DISCLOSURE WEB

One of the difficult aspects of U.S. tax law for foreign persons to understand is how they become accidental U.S. tax residents.  Even those here without a Green Card on non-immigration visas, can be required in any given year to … Continue reading

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CAUTION: IRS MAY ALREADY HAVE YOUR NAME OR WILL SOON. OFFSHORE DRAGNET LEADS UNNAMED FOREIGN BANKS TO COOPERATE

Some still out in the cold with offshore financial accounts take comfort in the fact that their bank has not yet been indicted or named in any publicly announced IRS investigation.  Well, here is some sobering news to shake confidence … Continue reading

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MORE STORM CLOUDS FOR HIDDEN OFFSHORE ACCOUNTS

The holes in which to hide for offshore tax cheats are steadily being filled up.  Those who have not entered the IRS Offshore Voluntary Disclosure Program, will find no comfort in some recent news, namely: Bank Frey, the “Truly Swiss, … Continue reading

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THE WRONG QUESTION TO ASK ABOUT OFFSHORE ACCOUNTS: WHAT ARE THE ODDS OF BEING CAUGHT?

In my post of July 14, 2013, “OVDP or Nothing At All,” I wrote: I believe the wiser approach for most is still to seek the shelter of certainty by entering the OVDP  (IRS 2012 OFFSHORE VOLUNTARY DISCLOSURE PROGRAM). I … Continue reading

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MORE ON GOVERNMENT SHUT DOWN IMPACT ON TAX FILINGS AND OVDP SUBMISSIONS

The IRS has updated in webpage with information, “IRS Operations During the Lapse in Appropriations.” http://www.irs.gov/uac/Newsroom/IRS-Operations-During-The-Lapse-In-appropriations Some additional guidance: E-filed returns will be processed normally although refunds will not be issued. Paper returns can be filed but will not be … Continue reading

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HEAT ON OFFSHORE TAX EVADERS TURNED UP: DOJ OFFERS SWISS GOVERNMENT SANCTIONED DEAL TO SMALLER SWISS BANKS

Recent developments have turned up the heat on offshore tax holders who have or have had unreported bank accounts in Switzerland: On August 29, 2013, the U.S. Department of Justice (DOJ) and Swiss Federal Department of Finance issued a joint … Continue reading

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NOOSE TIGHTENING ON UNREPORTED OFFSHORE ACCOUNT HOLDERS

August has been a busy month for weaving tighter the growing web of international snares laid for catching offshore tax evaders. On August 13, the U.S. and Cayman Islands announced agreement on a Model 1 Intergovernmental FATCA implementation agreement.  Under … Continue reading

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