Tag Archives: # INDIVISIBLE

IRS ADDS TWO MORE BAD BANKS TO ITS 50% LIST AND ISSUES FBAR PENALTY GUIDELINES

Posted on June 7, 2015 by steinbergtaxlaw

Bad Banks subject account holders to 50% penalty On June 3, 2015 the IRS added two more banks to its list of banks at which accounts subject the holder to a 50% OVDP miscellaneous offshore penalty on all offshore assets … Continue reading →

Posted in OFFSHORE VOLUNTARY DISCLOSURE PROGRAM, STREAMLINED FILING COMPLIANCE PROCEDURES, TAX CRIME STATUTE OF LIMITATIONS | Tagged , , , , , , , | Leave a comment

RESIDENCE OF PARTICIPANTS IN 2009 OVDP AND FOREIGN COUNTRIES IN WHICH DISCLOSED FINACIAL ACCOUNTS WERE LOCATED

Posted on February 21, 2014 by steinbergtaxlaw

On January 6, 2014 the U.S. Government Account Office (GAO) reported to Senator Carl Levin, Chairman, Permanent Subcommittee on Investigations, Committee on Homeland Security and Governmental Affairs, certain information about the participants in the 2009 IRS Offshore Voluntary Disclosure Program … Continue reading →

Posted in TAX | Tagged , , , , , , , , , , , , | Leave a comment

106 SWISS BANKS AGREE TO NAME NAMES OF US DEPOSITORS

Posted on February 7, 2014 by steinbergtaxlaw

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

Posted on January 24, 2014 by steinbergtaxlaw

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 →

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

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

Posted on January 17, 2014 by steinbergtaxlaw

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

AWARD FOR DUMBEST DIVORCING COUPLE

Posted on December 17, 2013 by steinbergtaxlaw

 I have seen divorcing spouses do really dumb things but this couple takes the cake and wins the award for Dumbest Divorcing Couple of the Year. The case Shai v. Shai was tried in Palm Beach County Florida before Acting … Continue reading →

Posted in DIVORCE, FBARS, JOINT RETURNS, MARRIED PERSONS, RETURNS, TAX, TAX CRIMES | Tagged , , , , , , , , | Leave a comment

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

Posted on December 12, 2013 by steinbergtaxlaw

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 →

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

DEPENDENCY EXEMPTION DENIED WHEN FORM 8332 RECEIVED WHEN IRS COULD NO LONGER ASSESS TAX AGAINST FORMER SPOUSE WHO HAD ALSO CLAIMED THE EXEMPTION

Posted on December 12, 2013 by steinbergtaxlaw

Tax Court Summary Decisions are not precedent but can be educational.  In David Charles Katz and Mary Joan Wring v. Commissioner, T.C. Summary Opinion 2013-98, the Tax Court again upheld the IRS denial of a dependency exemption when Form 8332 … Continue reading →

Posted in DEPENDENCY EXEMPTION, DIVORCE, TAX | Tagged , , , , , , , , | Leave a comment

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

Posted on November 20, 2013 by steinbergtaxlaw

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 | Tagged , , , , , , , , , , , , , , , , , | Leave a comment

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

Posted on November 15, 2013 by steinbergtaxlaw

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