Category Archives: VOLUNTARY DISCLOSURE

INITIAL THOUGHTS ON IRS CHANGES TO OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND STREAMLINED PROCESS FOR NON-WILLFUL TAXPAYERS

Yesterday, June 18, 2014, IRS announced and posted to the Offshore Voluntary Disclosure page on its website (www.irs.gov) significant changes to the 2012 OVDP reflected in revised Frequently Asked Questions; and, new Streamlined Filing Compliance Procedures for non-willful, out-of-compliance taxpayers, whether … Continue reading

Posted in 2012 OVDP, COMPLIANCE, FBARS, NEW OVDP, TAX, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , | 11 Comments

106 SWISS BANKS AGREE TO NAME NAMES OF US DEPOSITORS

My post of September 6, 2013, “Heat on Offshore Tax Evaders Turned up: DOJ Offers Swiss Government Sanctioned Deal to Smaller Swiss Banks,” described in some detail the Swiss Bank Settlement Program (SBSP) under which Swiss banks not already under … Continue reading

Posted in 2012 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, VOLUNTARY DISCLOSURE | Tagged , , , , , | Leave a comment

THE OFFSHORE DOMINOES ARE TUMBLING DOWN AND CREDIT SWISS WILL SOON FOLD

The Wall Street Journal reported today (“Credit Swiss Nears Tax-Cheat Deal,” by John Letzing, Francesco Guerrera and David Enrich) ) that Credit Swiss, Switzerland’s second largest bank, is said to be in serious negotiations with the Department of Justice to … Continue reading

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IT’S GOOD TO BE RICH: BEANIE BABY FOUNDER GOES FREE

Part T of the Federal Sentencing Guidelines Manual deals with “Offenses Involving Taxation.” The Introductory Commentary states: The criminal tax laws are designed to protect the public interest in preserving the integrity of the nation’s tax system.  Criminal tax prosecutions … Continue reading

Posted in 2011 OVDI, 2012 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, TAX CRIMES, VOLUNTARY DISCLOSURE | Tagged , , , , , , | Leave a comment

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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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

Posted in 2012 OVDP, AMENDED RETURNS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , | Leave a comment

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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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

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