A taxpayer who has not disclosed foreign bank accounts to the IRS can be charged with substantial miscellaneous Title 26 offshore penalties that ultimately can wipe out a taxpayer’s foreign assets. Disclosure is made by e-filing FinCEN Form 1114 (formerly Form TD F 90-22.1), Report of Foreign Bank and Financial Accounts (“FBAR”). The civil penalty […]
U.S. taxpayers with previously undisclosed interests in foreign financial accounts and assets continue to analyze and seek advice regarding the most appropriate methods of coming into compliance with their U.S. filing and reporting obligations. Many are pursuing participation in the current IRS Offshore Voluntary Disclosure Initiative known as OVDI (the current version began in 2012 […]
A taxpayer who has not disclosed foreign bank accounts to the IRS and to cure this delinquency and avoid criminal repercussions applies to the Offshore Voluntary Disclosure Initiative (“OVDI”), generally must pay a miscellaneous Title 26 offshore penalty, in lieu of traditional penalties that would apply to foreign assets or entities outside of OVDI. The […]
U.S. taxpayers living abroad qualifying for an automatic two-month extension must file their 2013 Federal individual income tax returns by Monday, June 16, 2014. The June 16th deadline applies in the following two situations: (1) U.S. citizens and resident aliens living overseas, or (2) U.S. taxpayers serving in the military outside the U.S. on the […]
Topics Covered: 1. Lessons learned from the criminal tax evasion Conviction of Rashia Wilson a/k/a “Queen Of IRS Tax Fraud”. 2. What should you do where you have undisclosed foreign bank accounts and unreported foreign income? 3. Understanding the IRS Criminal Investigation Process and what signs to be on the lookout for that you may […]
Credit Suisse Agrees to Pay $2.6 Billion to Settle Probe by U.S. Justice Department Credit Suisse Group AG became the first financial institution in more than a decade to plead guilty to a crime on May 19, 2014 when the Swiss bank admitted it conspired to aid tax evasion and agreed to pay $2.6 billion […]
Since the last quarter of 2013, an increasing number of U.S. taxpayers with accounts in Swiss banks have received letters from Swiss Banks regarding participation in the Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (the “Program”). The Program was established by the Department Of Justice (“DOJ”) and along with the provisions of […]
It is quite easy for U.S. Citizens and permanent residents (green card holders) who reside in a country other than the U.S. to either forget or not be aware of their U.S. tax obligations. The rules for filing income, estate and gift tax returns and for paying estimated tax are generally the same even if […]
Under the Foreign Account Tax Compliance Act (“FATCA”), foreign banks, insurers and investment funds must send the Internal Revenue Service information about Americans’ and U.S. permanent residents’ offshore accounts worth more than $50,000. Institutions that fail to comply could effectively be frozen out of U.S. markets. As of this blog posting, the U.S. has entered […]
In a world of CPA’s, tax preparers, enrolled agents, bookkeepers and accountants, it can be confusing to know when to hire a tax attorney. After all, you’re not hiring a tax lawyer to prepare your annual income tax return. So when and why would you need a tax attorney’s services? IRS And State Tax Disputes […]
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