Category Archives: TAX INFORMATION EXCHANGE AGREEMENTS

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

Posted on January 10, 2014 by taxpenaltylawyer

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

Posted on September 6, 2013 by taxpenaltylawyer

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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HOW DIFFICULT IS IT FOR A FOREIGN COUNTRY TO OBTAIN TAX INFORMATION UNDER AN INCOME TAX TREATY WITH THE U.S.?

Posted on August 26, 2013 by taxpenaltylawyer

Many non-residents or U.S. tax residents holding a passport of another country worry about the U.S. government sharing information about their U.S. financial activities with their home country. Solomon Juan Marcos Villarreal (Villlarreal), a Mexican national, tried to block the … Continue reading →

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NOOSE TIGHTENING ON UNREPORTED OFFSHORE ACCOUNT HOLDERS

Posted on August 17, 2013 by taxpenaltylawyer

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 →

Posted in 2012 OVDP, COMPLIANCE, FBARS, NEW OVDP, TAX, TAX INFORMATION EXCHANGE AGREEMENTS, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , | 2 Comments

THEY’LL SING NO MORE IN SINGAPORE

Posted on May 6, 2013 by taxpenaltylawyer

Tax cheats holding unreported offshore money in Singapore’s huge financial center will soon either sing no more or sing a sadder tune.  For as many Swiss banking clients were dumped by their bankers facing a new stricter global anti-tax evasion … Continue reading →

Posted in 2012 OVDP, FBARS, NEW OVDP, TAX, TAX CRIMES, TAX INFORMATION EXCHANGE AGREEMENTS, VOLUNTARY DISCLOSURE | Tagged , , , , , , | Leave a comment

IRS TO GET MORE EASY PICKINGS OF OFFSHORE FRUIT

Posted on March 23, 2013 by taxpenaltylawyer

Two high level IRS Criminal Investigation (CI) officials participated an American Bar Association, Tax Section, Webinar, “Criminal Tax Enforcement Hot Topics: The IRS Perspective,” (March 20, 2013).  Edward “Ted” Cronin is the Division Counsel/ Associates Chief Counsel (Criminal Tax) … Continue reading →

Posted in 2012 OVDP, AMENDED RETURNS, COMPLIANCE, DELINQUENT RETURN, FBARS, NEW OVDP, TAX, TAX CRIMES, TAX INFORMATION EXCHANGE AGREEMENTS, UNFILED RETURNS, VOLUNTARY DISCLOSURE | Tagged , , , , , , , | Leave a comment

STILL OUT IN THE COLD? IRS LEAVES OPEN DOOR FOR VOLUNTARY DISCLOSURE – 2012 OVDP

Posted on August 6, 2012 by taxpenaltylawyer

As Global Warming is said to be melting the arctic glaciers, safe havens for offshore tax scofflaws are dwindling from increasingly strident global economic pressure applied to tax haven jurisdictions. Now, tax haven countries wishing to participate in the global … Continue reading →

Posted in 2012 OVDP, DELINQUENT RETURN, FBARS, NEW OVDP, TAX, TAX CRIMES, TAX INFORMATION EXCHANGE AGREEMENTS, UNFILED RETURNS, VOLUNTARY DISCLOSURE | Tagged , , , , , | Leave a comment

MUCH OF LATIN AMERICA MAY YET BE A TAX INFORMATION BLACK HOLE

Posted on May 26, 2011 by taxpenaltylawyer

The U.S. and Panama have concluded a Tax Information Exchange Agreement that is now in effect.  The agreement signed in 2010 requires the delivery of information to the requesting country in all tax matters relevant to applying and collecting taxes and investigating and prosecuting … Continue reading →

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