A Texas court has dismissed a lawsuit against the IRS asserting that the IRS burden of proof to assess a $1.4M IRS offshore penalty had not been met. The IRS originally asserted that the plaintiff's failure to file an FBAR for his offshore accounts, assets and investments in 2008 was...
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...
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...
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...
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...
Improving Offshore Reporting and FBAR Compliance Top Priority for IRS
Improving offshore reporting and FBAR compliacne associated with foreign bank accounts, investments and income remains a top priority for the IRS according to IRS Commissioner John Koskinen. Commissioner Koskinen also said "Taxpayers here and abroad need to take their offshore tax and filing obligations seriously." What are those who continue to...
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...