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- STREAMLINED FILING VERSES REGULAR FILING WITH REASONABLE CAUSE STATEMENT
- CAUTIONARY TALE FOR POTENTIAL STREAMLINED FILERS AND ADVISORS
- OVDP TO END ON SEPT. 28, 2018 – ACT NOW ON UNDISCLOSED OFFSHORE ACCOUNTS
- PARADISE LOST: THE “PARADISE PAPERS LEAK REVEALS MODERN DIGITAL AGE TRUTHS – (1) ALL FINANCIAL RECORD CAN BE HACKED. 92) THERE ARE NO CYBER SECRETS. AN OVDP SOLUTION FOR OFFSHORE NONCOMPLIANCE
- DEPARTMENT OF JUSTICE ANNOUNCES FBAR GUILTY PLEA OF GREEN CARD HOLDER
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Tag Archives: FBAR
IRS OFFICIALS ANSWER CIVIL AND CRIMINAL OFFSHORE QUESTIONS
On February 24, 2015 I participated in an ABA Tax Section Webinar, “Answering Your Criminal and Civil Offshore Disclosure Questions.” On the Webinar panel were two IRS officials: David W. Horton, Director, IRS International Individual Compliance; and John C. McDougal, … Continue reading →
Posted in 2014 OVDP, DELINQUENT RETURN, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, STREAMLINED FILING COMPLIANCE PROCEDURES, STREAMLINED FILING COMPLIANCE PROCEDURES, TAX, VOLUNTARY DISCLOSURE
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Tagged AMENDED RETURNS, FBAR, FBAR PENALTIES, FOREIGN BANK ACCOUNTS, IRS STREAMLINED FILING COMPLIANCE PROCEDURES, NEW STREAMLINED PROCESS FOR OFFSHORE ACCOUNTS, OFFSHORE BANK ACCOUNTS, OFFSHORE TAX FRAUD, OVDP, QUIET DISCLOSURES, REASONABLE CAUSE, ROBERT S STIENBERG, SWISS BANK SETTLEMENT PROGRAM, VOLUNTARY DISCLOSURE, WILLFULNESS
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IRS UNRELENTING IN PURSUIT OF UNREPORTED OFFSHORE ACCOUNTS
Today the IRS released IR-2015-9, “Hiding Money or Income Offshore Among the “Dirty Dozen” List of Tax Scams for the 2015 Filing Season” which provides verbatim: WASHINGTON — The Internal Revenue Service today said avoiding taxes by hiding money or … Continue reading →
SOME SWISS BANKS ARE MORE THAN ENCOURAGING U.S. CLIENTS TO ENTER THE OVDP – THEY ARE OFFERING FINANCIAL INCENTIVES
An article in the Wall Street Journal on July 19, 2014 by John Letzing (“Taxpayers Get Incentives to Report: Swiss Banks Aim to Entice Americans to Disclose Accounts to IRS by Helping Cover Costs, Penalties”), reveals what many professionals have … Continue reading →
Posted in 2012 OVDP, 214 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, TAX CRIMES, VOLUNTARY DISCLOSURE
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Tagged 2012 OVDP, BANK SECRECY ACT, FBAR, FBAR PENALTIES, FOREIGN BANK ACCOUNTS, OFFSHORE ACCOUNTS, OFFSHORE TAX FRAUD, OVDP, ROBERT S STIENBERG, SWISS BANK FINANCIAL INCENTIVES, SWISS BANK SETTLEMENT PROGRAM, TAX CRIMES, VOLUNTARY DISCLOSURE
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THE TAX LAW IS COMPLEX; OFFSHORE COMPLIANCE DECISIONS ARE DIFFICULT AND MISTAKES CAN HAVE GRAVE CONSEQUENCES
John J. Scroggin published an interesting and entertaining survey of tax complexity in the Wealth Strategies Journal (Tax Complexity, History, and Humor, July 8, 2014). The article begins with a quote from Judge Learned Hand: “In my own case the … Continue reading →
Posted in 214 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, VOLUNTARY DISCLOSURE
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Tagged COMPEXITY OF OVDP DECISIONS, FBAR, FBAR PENALTIES, FOREIGN BANK ACCOUNTS, OFFSHORE ACCOUNTS, OFFSHORE BANK ACCOUNTS, OFFSHORE TAX FRAUD, OVDP, OVDP BENEFITS, OVDP OPT OUT, QUIET DISCLOSURES, Robert S. Steinberg, TAX COMPLEXITY
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STILL HAVE AN UNREPORTED FORIEGN FINANCIAL ACCOUNT? BEWARE THE TRUSTED ADVISORS: THEY WILL GIVE YOU UP TO SAVE THEIR OWN SKINS
The DOJ Press Release reproduced below in its entirety should be very scary to those still out in the cold with unreported foreign financial accounts. We know that foreign banks are taking steps to minimize their risk of criminal prosecution … Continue reading →
Posted in 2012 OVDP, 214 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX CRIMES, VOLUNTARY DISCLOSURE
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Tagged 2012 OVDP, BANK SECRECY ACT, FBAR, FBAR PENALTIES, FOREIGN BANK ACCOUNTS, OFFSHORE ACCOUNTS, OFFSHORE BANK ACCOUNTS, OFFSHORE TAX FRAUD, OVDP, OVDP BENEFITS, ROBERT S STIENBERG, SWISS BANKS, TAX CRIMES, VOLUNTARY DISCLOSURE
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SOME ADVANTAGES AND DISADVANTAGES OF STREAMLINED PROCEDURES FOR U.S. CITIZENS AND RESIDENTS RESIDING IN THE U.S.
“Beware of false knowledge; it is more dangerous than ignorance.” – George Bernard Shaw Shaw’s admonition is applicable to the recently announced Streamlined Process and Transitional as alternatives for resolving offshore noncompliance exposure of U.S. citizens and residents. Calls I’ve … Continue reading →
Posted in 2012 OVDP, 214 OVDP, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, TAX CRIMES
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Tagged BANK SECRECY ACT, FBAR, FBAR PENALTIES, FOREIGN BANK ACCOUNTS, NEW STREAMLINED PROCESS FOR OFFSHORE ACCOUNTS, NEW TRANSITIONAL RULES FOR OFFSHORE ACCOUNTS, OFFSHORE ACCOUNTS, OFFSHORE TAX FRAUD, OVDP, OVDP BENEFITS, OVDP OPT OUT, QUIET DISCLOSURES, Robert S. Steinberg, VOLUNTARY DISCLOSURE
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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
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Tagged 2012 OVDP, CHANGES IN OVDP PROCEDURES, FBAR, FBAR PENALTIES, FOREIGN BANK ACCOUNTS, OFFSHORE ACCOUNTS, OFFSHORE TAX FRAUD, OVDP BENEFITS, OVDP OPT OUT, QUIET DISCLOSURES, REASONABLE CAUSE, Robert S. Steinberg, STREAMLINED FILING COMPLIANCE PROCEDURES
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11 Comments
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 →
Posted in 2012 OVDP, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, TAX INFORMATION EXCHANGE AGREEMENTS, VOLUNTARY DISCLOSURE
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Tagged 2012 OVDP, BANK SECRECY ACT, FATCA, FBAR, FBAR PENALTIES, FBARS, FOREIGN BANK ACCOUNTS, OFFSHORE ACCOUNTS, OFFSHORE BANK ACCOUNTS, OFFSHORE TAX FRAUD, OVDP, OVDP BENEFITS, RAOUL WEIL, Robert S. Steinberg, SWISS BANK SETTLEMENT PROGRAM, SWISS BANKS, TAX HAVENS, VOLUNTARY DISCLOSURE
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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 →
Posted in 2012 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, VOLUNTARY DISCLOSURE
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Tagged # INDIVISIBLE, 2012 OVDP, BANK SECRECY ACT, FATCA, FBAR, FBAR PENALTIES, FBARS, FOREIGN BANK ACCOUNTS, OFFSHORE ACCOUNTS, OFFSHORE BANK ACCOUNTS, OFFSHORE TAX FRAUD, OVDP, OVDP BENEFITS, Robert S. Steinberg, SWISS BANKS, TAX CRIMES, UBS, VOLUNTARY DISCLOSURE
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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
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Tagged # INDIVISIBLE, FBAR, FBAR PENALTIES, NON-RESIDENT ALIEN, OVDP OPT OUT, QUIET DISCLOSURES, REASONABLE CAUSE, RESIDENT ALIEN, Robert S. Steinberg, SUBSTANTIAL PRESENCE TEST, TD F 90.22-1
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