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Tag Archives: QUIET DISCLOSURES
IRS NOOSE TIGHTENS ON THOSE WITH UNREPORTED OFFSHORE ACCOUNTS: CARIBBEAN AND AUSTRALIAN ACCOUNT HOLDERS AT GREAT RISK
The IRS continues to cast a wider net for offshore tax cheats and continues to make the cost of waiting to come into compliance expensive. Some recent developments illustrate: Tax storm in the Caribbean: The IRS had previously served a … Continue reading →
Posted in OFFSHORE BANK ACCOUNTS
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Tagged AUSTRALIA DISCLOSES US ACCOUNT HOLDERS, BELIZE BANK SUMMONS, CIBC, COMPETENT AUTHORITY AGREEMENTS UNDER FATCA IGAS, DELINQUENT FBAR SUBMISSION PROCEDURES, DELINQUENT INTERNATIONAL INFORMATION RETURN PROCEDURES, IRS STREAMLINED FILING COMPLIANCE PROCEDURES, LIST OF BAD BANKS, OVDP - 50% PENALTY, QUIET DISCLOSURES, REASONABLE CAUSE
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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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EVALUATING RISK OF PROSECUTION OUTSIDE OF THE OVDP
An article authored by Edward Robbins, Jr. Steven Toscher and Dennis Perez, “What’s Your Client’s Criminal Exposure on His Undeclared Foreign Bank Account? (Journal of Tax Practice, October – November 2012 pp 67-74), astutely summarizes the most likely charged tax … Continue reading →
Posted in 214 OVDP, FBARS, OFFSHORE BANK ACCOUNTS, TAX, VOLUNTARY DISCLOSURE
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Tagged BANK SECRECY ACT, FBAR PENALTIES, FOREIGN BANK ACCOUNTS, IRS STREAMLINED FILING COMPLIANCE PROCEDURES, OVDP, OVDP BENEFITS, QUIET DISCLOSURES, RISK OF PROSECUTION IN OFFSHORE CASE, ROBERT S STIENBERG, TAX CRIMES, VOLUNTARY DISCLOSURE, WILLFULNESS
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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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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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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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OVDP OR NOTHING AT ALL
The 1939 song, “All or Nothing at All,” (by Arthur Altman and Jack Lawrence) made popular by Frank Sinatra might be sung in a new version by IRS, “OVDP or Nothing at All.” The Bank Secrecy Act contains draconian penalties … Continue reading →
Posted in 2012 OVDP, AMENDED RETURNS, DELINQUENT RETURN, FBARS, NEW OVDP, TAX, TAX CRIMES, VOLUNTARY DISCLOSURE
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Tagged # INDIVISIBLE, BANK SECRECY ACT, EIGHTH AMENDMENT, EXCESSIVE FINES, FBAR, FBAR PENALTY, FORFIETURE, OVDP OPT OUT, QUIET DISCLOSURES, Robert S. Steinberg, U.S. V ZWERNER, U.S. V. BAJAKAJIAN, VOLUNTARY DISCLOSURE
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ARE OFFSHORE CHEATS GETTING OFF TOO EASY?
A recent Wall Street Journal Article, “Leniency for Offshore Cheats,” by Laura Saunders cited statistics that reveal a discrepancy between sentences handed down in offshore cases versus those dolled out in tax shelter criminal cases. The article reports: The average … Continue reading →
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