The US Treasury Department and the IRS to propose changes to offshore business taxes and a practice known as "Inversion." A hearing yesterday brought stiff resistance from representatives in the business community and others seeking to preserve offshore tax advantages. "Inversion" is one of the specific strategies addressed in the...
US Justice Department Wins First FATCA Legal Victory – Shell Company and Its Nominees
Last week, the US Justice Department announced its first FATCA Legal Victory when it announced that Gregg R. Mulholland, owner of an offshore investment management company based out of Panama and Belize has plead guilty to money laundering and conspiracy. The firm was accused of fraudulent behavior, manipulating the value of...
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...
What are the Panama Papers and What Picture Do They Paint of Offshore Tax Havens and the IRS?
In the past few days, news of the "Panama Papers" has revealed more than 11 million documents which contain private offshore banking information of many of the world's rich and famous. The papers reveal the offshore efforts to shelter income and assets of many world leaders and some of the...
IRS Increases Tactics to Gain Access to Offshore Bank Records
The IRS adds many banks and financial institutions each month to the tens of thousands of tax and finance sources worldwide who have agreed to provide information directly to the IRS regarding the account balances and activities of US taxpayers overseas. Recently, the IRS aggressively expanded its tactics, issuing a...
US Has Now Reached FATCA Agreements with 75 Swiss Banks
An agreement reached just before Christmas means that the US has reached FATCA agreements with 75 Swiss banks. The US Department of Justice has confirmed penalties exceeding $178 Million from 4 Swiss bank agreements including: Banque Cantonal du Valais (BC Valais) Gonet & Cie or simply Gonet Bank J. Safra...
Over 177,000 Offshore Banks and Institutions Providing Financial Information to the IRS
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Wednesday, December 2, 2015. The IRS has announced that FATCA agreements have led to the exchange of financial information regarding US taxpayers with 177,147 institutions in more than 200 sovereign nations and legal jurisdictions. The list...
IRS Adds More Swiss Banks to Automatic 50% OVDP Penalty List
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Tuesday, June 9, 2015. The IRS has added severl new Swiss banks to the list of institutions that carry a mandatory 50% penalty instead of the 27.5% penalty provided in most OVDP filings. It doesn't matter...
Less Than One Month Remains To File Under the OVDP Streamlined Domestic Offshore Procedures
By Janathan L. Allen, APC of Janathan L. Allen, APC posted in FATCA on Thursday, July 17, 2014. August 4 is the due date for those who wish to submit an application to the IRS under the Streamlined Domestic Offshore Procedures of the OVDP and avoid the increased foreign account...