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...
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...
I Didn’t Know I needed to File an FBAR – Is That Non-Willful Conduct?
I hear it often - from dinner parties to fellow travelers to those who simply call for advice: "I didn't know I needed to file an FBAR." The next questions that follows are often: "This isn't that big of a deal is it? Can I simply catch up on my past FBARs and...
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...
IRS Voluntary Offshore Disclosures under the Streamlined Program Receive Disturbing News
We have been at the forefront of the IRS crackdown on offshore bank accounts, foreign investments and corporate ownership and the requirement for US taxpayers to come into compliance with FBAR reporting and associated IRS offshore voluntary disclosures. For those who have decided to file IRS voluntary offshore disclosures under the...
Do All IRS FBAR Filers Need to Consider a Voluntary Disclosure or OVDP?
Yesterday, we discussed the rapidly rising number of “Report of Foreign Bank and Financial Reports” or FBARs filed in 2015. This continues a five year rising trend, and demonstrates the number of US taxpayers with offshore bank accounts and international investments. It also leads to a serious question for FBAR filers:...
IRS Adds Banks to the List of 50% OVDP Penalty Institutions
The IRS continues to add more and more international banks, financial and investment firms to its list of 50% OVDP penalty institutions each month. The list is based upon the IRS' determination that the bank or institution has actively helped US taxpayers to shelter income or avoid paying US taxes....
IRS Adds 7 More Swiss Banks to 50% OVDP Penalty List
The IRS has added 7 more Swiss banks to the 50% OVDP Penalty List in December, and now more than 100 Swiss banks are providing information about US taxpayers accounts and transactions directly to the IRS. For those US taxpayers who have already come into FBAR compliance with the IRS...
Why Should US Taxpayers With Offshore Accounts and Assets Be Cautious When Considering the Streamlined Domestic Offshore Procedures?
Why shouldn't every US taxpayer with offshore accounts or assets choose the Streamlined Domestic Offshore Procedures when coming into compliance with the IRS and FBAR reporting requirements under FATCA? Why wouldn't a US taxpayer simply want to claim "non-willful" conduct in their disclosures of offshore bank accounts, investments and assets...