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...
Is the IRS Offshore Voluntary Disclosure Program or OVDP the Right Alternative for FBAR Compliance?
FATCA has completely changed the international financial landscape - from FBAR crackdowns to the "Panama Papers." Recently, many people have asked "Is the IRS Offshore Voluntary Disclosure Program or OVDP the right alternative for FBAR compliance or should I/we consider the streamlined application? The central question from the perspective of...
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...
US Taxpayers Identified in Panama Papers Should Immediately File OVDP
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...
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...
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...
Record Number of FBARs Filed in 2015 – up 8% over 2014
The IRS has reported that the number of "Report of Foreign Bank and Financial Reports" or FBARs filed in 2015 is up by more than 8 percent over 2014. A staggering 1,163,229 FBARs were filed with the IRS, continuing the trend of an increasing number of US taxpayers filing the...