Tag Archives: OFFSHORE BANK ACCOUNTS

WAITING IS A DANGEROUS GAME FOR THOSE STILL NOT IN COMPLIANCE WITH FOREIGN REPORTING RULES

Posted on April 26, 2016 by taxpenaltylawyer

Over 55,000 taxpayers have come into compliance by entering the Offshore Voluntary Disclosure Program. An untold number of less culpable non-willful taxpayers have come into compliance under the Streamlined Filing Compliance Procedures.  Some with reasonable cause have used the delinquent … Continue reading →

Posted in OFFSHORE VOLUNTARY DISCLOSURE PROGRAM, STREAMLINED FILING COMPLIANCE PROCEDURES, Uncategorized | Tagged , , , , , , | Leave a comment

IRS OFFICIALS ANSWER CIVIL AND CRIMINAL OFFSHORE QUESTIONS

Posted on February 26, 2015 by taxpenaltylawyer

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 | Tagged , , , , , , , , , , , , , , | 8 Comments

SOME CLARIFICATION FROM IRS ON THE STREAMLINED FILING COMPLIANCE PROCEDURES.AND DEINQUENT INTERNATIONAL INFORMATION RETURN SUBMISSIONS.

Posted on November 9, 2014 by taxpenaltylawyer

The IRS has updated its Streamlined Filing Compliance Procedures and Delinquent International Information Return pages (October 9, 2014) and issued Frequently Asked Questions with regard to each. The FAQs for U.S. Taxpayers residing in the U.S. clarify that: The 5% … Continue reading →

Posted in 214 OVDP, COMPLIANCE, FBARS, OFFSHORE BANK ACCOUNTS, TAX | Tagged , , , , , , , , | 1 Comment

WILL-O -THE WISP NON-WILLFULNESS IN THE STREAMLINED FILING COMPLIANCE PROCEDURE

Posted on September 1, 2014 by taxpenaltylawyer

“A will-o’-the-wisp is an atmospheric ghost-light seen… at night, especially over bogs, swamps or marshes. It resembles a flickering lamp and is said to recede if approached, drawing (sojourners) from the safe paths.”(Wilkipedia).  Most clients with unreported offshore accounts who … Continue reading →

Posted in TAX | Tagged , , , , , , , , , , , , , , , | 4 Comments

THE TAX LAW IS COMPLEX; OFFSHORE COMPLIANCE DECISIONS ARE DIFFICULT AND MISTAKES CAN HAVE GRAVE CONSEQUENCES

Posted on July 18, 2014 by taxpenaltylawyer

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

STILL HAVE AN UNREPORTED FORIEGN FINANCIAL ACCOUNT? BEWARE THE TRUSTED ADVISORS: THEY WILL GIVE YOU UP TO SAVE THEIR OWN SKINS

Posted on July 6, 2014 by taxpenaltylawyer

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 | Tagged , , , , , , , , , , , , , | 2 Comments

ON FBAR WILLUL NON-FILING AND WILLFUL BLINDNESS – THE RUMSFELD DISCLAIMER

Posted on April 23, 2014 by taxpenaltylawyer

In United States v. Williams, (2012), the Fourth Circuit Court of Appeals reversed the District Court’s holding that Williams’ failure to file an FBAR that was due June 30, 2001 was a non-willful failure to file because the government already … Continue reading →

Posted in 2012 OVDP, FBARS, JOINT RETURNS, NEW OVDP, OFFSHORE BANK ACCOUNTS, POLICY, RETURNS, TAX | 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 taxpenaltylawyer

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 taxpenaltylawyer

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

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 →

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