One thing is clear about the massive release of additional documents in the "Panama Papers" scandal yesterday: It's only a matter of time. There are several US taxpayers identified in yesterday's information release who should seriously consider their position and immediately file OVDP application to avoid potential criminal exposure for tax...
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36 US Taxpayers Exposed for Tax Fraud by Panama Papers
A new batch of data in the "Panama Papers" was released this morning by the International Consortium of Journalists - the group of international journalists who is managing the editing and release of 11.5 million documents collectively known as the Panama Papers. 36 US taxpayers were among those exposed for...
The Swiss Are Providing the IRS with Direct Feeds on US Taxpayer Accounts
There are very few safe tax havens left in the world, and the vast majority of the Swiss financial houses, banks and investment management companies are providing the IRS with direct feeds on US taxpayer accounts. This information includes account information, balances, and transactional data. The Swiss institutions have agreed to...
Business Contracts Shouldn’t Be Downloaded or Repurposed
Business contracts are the foundation of successful transactions or relationships, and should never be downloaded, or copied and re-purposed from a previous business experience. A contract establishes the complete basis of the relationship between the parties, the responsibility of each and the "benefit of the bargain" each expects to receive...
How Has the IRS FBAR Definition of “Non-Willful” Changed?
Why has the IRS questioned or outright rejected many of the applications under the Streamlined Domestic Offshore procedures? How has the IRS FBAR definition of "non-willful" changed? Previously the forms associated with the streamlined domestic offshore procedures (IRS Forms 14653 and 14654) simply asked the taxpayer to "provide specific reasons...
FATCA Rules May Make a US Trust Taxable as a Foreign Trust
Is it possible that a trust established under the laws of a US State such as California, with a US agent serving as its trustee could be forced to file taxes as a foreign trust? Yes, Under the Foreign Account Tax Compliance Act or FATCA rules and federal law if...
IRS Receiving Treasure Trove of US Taxpayer Offshore Account Information
The IRS reports that it is receiving a vast amount of offshore account information from foreign banks, investment institutions and sovereign tax authorities regarding US taxpayers. The information is quite detailed and linked to individual taxpayer IDs, and includes data such as account information, balances (present and historical), transactions as...
Business Contracts Increase Profits in San Diego
How can business contracts increase profits for San Diego businesses? Why shouldn't a business save a few dollars and download a contract or "borrow" one off of the internet? Your company's business contracts are the foundation and lifeblood of your organization. The quality of your contracts will determine your long...
IRS Changes Streamlined Domestic Offshore Procedures Forms
The IRS has made significant changes to the forms associated with the Streamlined Domestic Offshore Procedures, a voluntary disclosure to the US government of offshore accounts, assets and income. The streamlined program was designated for US taxpayers who exhibited "non-willful" conduct in terms of why they failed to report offshore...