THE CARROT & STICK APPROACH TO PARTICIPATION IN THE OVDI PROGRAM: IRS OFFSHORE COMPLIANCE AUDITS
|
|
- Belinda Hicks
- 8 years ago
- Views:
Transcription
1 THE CARROT & STICK APPROACH TO PARTICIPATION IN THE OVDI PROGRAM: IRS OFFSHORE COMPLIANCE AUDITS By Richard J. Sapinski Sills Cummis & Gross P. C. Newark, NJ
2 Between February 2009 and early 2010, UBS provided initially 285 names of U.S. numbered account clients and ultimately an additional 4,450. In June 2011 IRS began audits of U.S. Taxpayers who had UBS accounts but did not come into the 2009 OVDI Many of these audits are STILL in progress In April 2011 IRS served a John Doe Summons on HSBC seeking the names of US Taxpayers with accounts at HSBC (India) IRS is reportedly now beginning audits on U.S. clients of Indian banks
3 Background In March 2009, IRS announced the 2009 Offshore Voluntary Disclosure Initiative ( 2009 OVDI ) through which U.S. customers of UBS or other foreign banks who had not been compliant could: 1. Avoid potential criminal prosecution and 2. Limit their civil exposure for unpaid taxes and penalties.
4 The 2009 OVDI Program Taxpayers who wished to participate in the 2009 OVDI had to: 1. Request pre-clearance from IRS-CI (to confirm the Taxpayer was not already under audit or investigation or known to IRS) 2. Provide a written submission (signed under penalties of perjury) to IRS-CI detailing the nature and extent of the Taxpayer s offshore activities.
5 3. Obtain IRS-CI Preliminary Acceptance of the case as a voluntary disclosure. 4. File 6 years of amended tax returns ( ) and 6 years of delinquent or amended FBARs ( ). 5. Fully pay the tax due on the Forms 1040X plus a 20% accuracy-related penalty on the tax plus interest. 6. Pay an FBAR-substitute penalty of 20% of the highest aggregate balance of the Taxpayer s foreign accounts (and/or other foreign assets) within the 6 year OVDI period.
6 Consequences of Non-Participation in 2009 OVDI IRS issued written guidance about the 2009 OVDI in which it warned Taxpayers that those who did not participate in the 2009 OVDI and either did nothing or attempted to do a quiet disclosure (file one or more years amended returns and FBARs without formally notifying IRS that the purpose was to correct offshore non-reporting) that IRS was actively attempting to identify them and, if caught, they would face possible criminal prosecution or, at best, would be subjected to intensive audit and face maximum civil penalties.
7 IRS Post 2009 OVDI Enforcement Efforts 2009 OVDI ended 10/15/09 with approximately 15,000 U.S. Taxpayers participating. IRS continued its offshore enforcement efforts in Switzerland and expanded them to other countries where it believes U.S. Taxpayers have maintained undisclosed accounts or assets in order to avoid or evade their U.S. tax obligations.
8 Subsequent IRS enforcement actions are known to have focused on accounts in: India Israel Lichtenstein Pacific Rim (Hong Kong, Singapore, etc.) IRS also has aggressively pursued small Swiss banks without U.S. offices which have been used by U.S. Taxpayers fleeing UBS or other major banks. Currently 14 foreign banks have either acknowledged being under investigate or have been identified in press reports as being under investigation.
9 IRS Reopens the OVDI Program IRS reopened the OVDI in 2011 for 8 months (2011 OVDI) and reopened it again indefinitely in January 2012 ( 2012 OVDI ) However, IRS reserved the right to close the 2012 OVDI to certain classes of U. S. Taxpayers without notice (including customers of certain banks or Taxpayers with accounts in certain countries) but to date has not done so.
10 Current OVDI Requirements The 2011 and 2012 OVDI Programs were more onerous than the original 2009 OVDI Program. 8 years of amended returns/fbars required (vs. 6 years in 2009 OVDI) FBAR-substitute penalty raised to 25% (2011) and then to 27-1/2% (2012) of highest value of offshore assets during the 8-year OVDI period (vs. 20% in 2009 OVDI). Nonetheless, an additional approximately 20,000 U. S. Taxpayers have participated in the 2011 and 2012 programs and the total collected by IRS to date through these programs exceeds $5 Billion.
11 IRS Efforts to Identify Non- Participating Taxpayers To validate the 2009, 2011 and 2012 OVDI Programs, IRS has aggressively sought to identify U. S. Taxpayers who should have participated but did not do so. o Once identified, the IRS has either opened a Criminal investigation of the U. S. Taxpayer (either in conjunction with the Dept. of Justice Tax Division or separately as an Administrative Investigation) or sent out audit notices to U. S. Taxpayers who IRS believes have not reported their foreign accounts or income.
12 The IRS has assigned both agents from the International Individual Compliance (IIC) Unit of the Large Business & International (LB&I) Division and specially detailed Revenue Agents from its regular Small Business/Self- Employed (SB/SE) Division to conduct audits of these U. S. Taxpayers
13 Sources of Information for IRS About Non-Participating Taxpayers Information Provided by Foreign Banks Pursuant Non-Prosecution or Deferred Prosecution Agreements Negotiated with the Tax Division of the Dept. of Justice (UBS) John Doe Summonses issued to either U.S. branches of foreign banks or their U.S. correspondent banks. (HSBC, Wegelin, Bank Frey, Zuricher Kantonal) Information Stolen by bank employees and sold to U.S. or other governments (LGT)
14 Information Provided by Foreign Bankers or Investment Advisors Negotiating Their own deals with the Justice Dept. (Credit Suisse) Suspicious Activity Reports filed by U.S. banks on unusual account activity by their Customers (foreign wire transfers, cash deposits being made to repatriate the money outside of OVDI)
15 How Do I Tell If The Audit Is Offshore-Related o o Audit letter appears routine and does not notify the Taxpayer of the nature/origin of the examination. However, the Initial IDR request is unusually detailed and asks that copies of all bank accounts for the year under audit as well as any financial statements or loan applications, AND the Taxpayer him/herself be at the first meeting.
16 TELLTALE INDICATIONS OF REAL ORIGIN OF THE AUDIT The IRS agent who sent the audit letter is from the IRS LB&I Division and the Taxpayer is not otherwise an LB&I Taxpayer (not a business with assets over $10,000,000). The agent is located outside New Jersey (California, Texas or Florida) but refuses to transfer the audit to New Jersey or explain why not. If a New Jersey SB/SE agent is assigned, the agent may be located in either Paramus or Fairfield, New Jersey but is auditing a Taxpayer elsewhere in the state. IRS Agent will insist on meeting and interviewing the Taxpayer and be willing to travel even from out of state to do so.
17 IRS will Summons the Taxpayer if the request for interview is not granted. IRS will request information for and examine years outside of the year stated in the audit letter. IRS agent will not (usually) explain why he/she must interview the Taxpayer, disclose the questions in advance, provide copies of what information IRS has nor even disclose (in most cases) that it has any information. o ask your client, he/she knows what he/she why he is being audited and knows what has or doesn t have that is responsive."
18 PUNITIVE PENALTY ASSERTIONS In many cases, IRS will assert civil fraud (75% of tax) penalties and maximum FBAR penalties (50%/year on that year s highest balance) based on the Taxpayer either admitting to having undisclosed foreign accounts or lying and denying having them ( damned if you do/damned if you don t).
19 Other Risks/Unique Features Possible criminal referral from auditor to IRS-CI. Required Records Doctrine being used by the Dept. of Justice to compel Taxpayers to produce foreign account records despite the obvious Fifth Amendment implications of doing so. IRS Rigid Attitude to Resolving the Audit in an Expeditious Way (Short of full Taxpayer concession of wrongdoing). IRS Counsel attorney working with the auditor in developing the case. Preparer Obligations and Potential Issues
The Crackdown On Undeclared Foreign Bank Accounts
Portfolio Media. Inc. 860 Broadway, 6th Floor New York, NY 10003 www.law360.com Phone: +1 646 783 7100 Fax: +1 646 783 7161 customerservice@law360.com The Crackdown On Undeclared Foreign Bank Accounts
More informationFOREIGN INCOME, ASSETS, AND IRS AMNESTY PROGRAMS
FOREIGN INCOME, ASSETS, AND IRS AMNESTY PROGRAMS Ahuja & Clark, PLLC By: Madhu Ahuja, CPA, CVA, CFE Ravi Modi, CPA www.ahujaclark.com WHO IS SUBJECT TO TAX FILING REQUIREMENTS? U.S. Citizen and Green Card
More informationhttp://www.justice.gov/tax/offshore-compliance-initiative
Page 1 of 8 OFFSHORE COMPLIANCE INITIATIVE One of the Tax Division's top litigation priorities is combatting the serious problem of non-compliance with our tax laws by U.S. taxpayers using secret offshore
More informationGAO OFFSHORE TAX EVASION. IRS Has Collected Billions of Dollars, but May be Missing Continued Evasion. Report to Congressional Requesters
GAO United States Government Accountability Office Report to Congressional Requesters March 2013 OFFSHORE TAX EVASION IRS Has Collected Billions of Dollars, but May be Missing Continued Evasion GAO-13-318
More informationNew York Law School April 24, 2015. Professor Alan I. Appel New York Law School
Undisclosed Foreign Accounts: IRS Investigations, Audits, OVDP and Streamlined Disclosures The Lawyer s Role in Guiding the Taxpayer through Perilous Waters New York Law School April 24, 2015 Professor
More informationROGERS JOSEPH O'DONNELL
415.956.2828 (t) Robert Dollar Building 415.956.6457 (f) 311 California Street, 10th Flr. San Francisco CA 94104 ROGERS JOSEPH O'DONNELL 202.777.8950 (t) Victor Building 202.347.8429 (f) 750 9th Street,
More informationOriginal Frequently Asked Questions Posted May 6, 2009. 1. Why did the IRS issue internal guidance regarding offshore activities now?
Original Frequently Asked Questions Posted May 6, 2009 1. Why did the IRS issue internal guidance regarding offshore activities now? The IRS has had a voluntary disclosure practice in its Criminal Manual
More informationOverview of 2011 IRS Offshore Voluntary Disclosure Initiative
Overview of 2011 IRS Offshore Voluntary Disclosure Initiative Attorney Morris N. Robinson, CPA, LLM M. Robinson & Company MassTaxLawyers.com 160 Federal Street Boston, MA 02110 617/ 428-6900 1 M. Robinson
More informationUnited States Attorney s Office Southern District of New York Offshore Tax Evasion Initiative
United States Attorney s Office Southern District of New York Offshore Tax Evasion Initiative Daniel W. Levy Assistant United States Attorney Prosecutions of Account-Holders SDNY Prosecutions of Account-Holders
More informationCorrecting IRS Income Tax and Foreign Asset Reporting Problems
Correcting IRS Income Tax and Foreign Asset Reporting Problems D. Sean McMahon, JD, LLM Boston, Massachusetts www.mcmahontaxlaw.com D. Sean McMahon Former Senior Attorney with the IRS Office of Chief Counsel
More informationSecret Swiss Accounts Said No Longer Safe for Tax
1 of 5 9/11/2013 1:35 PM Secret Swiss Accounts Said No Longer Safe for Tax Dodging By David Voreacos - Sep 8, 2013 Taxpayers who still believe they can hide secret Swiss bank accounts from the Internal
More information8 THINGS YOU MUST KNOW BEFORE THE IRS CALLS YOU
8 THINGS YOU MUST KNOW BEFORE THE IRS CALLS YOU Contact Us Today to Schedule a Free Consultation. Call 866-784-0023 or visit www.mlhorwitzlaw.com 8 Things You Must Know Before the IRS Calls You What is
More informationIRS Offshore Voluntary Disclosure Program Practical Q&A
Legal Update IRS Offshore Voluntary Disclosure Program Practical Q&A March 2012 On January 9, 2012, the IRS reopened its Offshore Voluntary Disclosure Program ("OVDP"), a limited federal income tax amnesty
More informationIRS ANNOUNCES NEW VOLUNTARY DISCLOSURE DEAL FOR OFFSHORE ACCOUNT HOLDERS SEPTEMBER 23, 2009 DEADLINE Richard G. Convicer, Esq. Eric L. Green, Esq.
IRS ANNOUNCES NEW VOLUNTARY DISCLOSURE DEAL FOR OFFSHORE ACCOUNT HOLDERS SEPTEMBER 23, 2009 DEADLINE Richard G. Convicer, Esq. Eric L. Green, Esq. On March 23, 2009 the Internal Revenue Service announced
More informationUnited States v. Wegelin & Co. 12 Cr. 02 (JSR) Daniel W. Levy Assistant United States Attorney Southern District of New York
United States v. Wegelin & Co. 12 Cr. 02 (JSR) Daniel W. Levy Assistant United States Attorney Southern District of New York Wegelin & Co. Oldest Swiss bank founded 1741 True partnership 8 managing partners
More informationIn February of 2011 the IRS announced a partial
Offshore Voluntary Disclosure The Next Generation By Dennis Brager Dennis Brager examines the next generation of partial tax amnesty for taxpayers who have failed to meet the myriad of disclosure requirements
More informationPRESS RELEASE. Internal Revenue Service - Criminal Investigation Chief Richard Weber
PRESS RELEASE Internal Revenue Service - Criminal Investigation Chief Richard Weber Date: Nov. 19, 2015 Contact: CI Release #: *CI-HQ-COMMUNICATIONSEDUCATION@ci.irs.gov IRS Criminal Investigation CI-2015-11-19-A
More informationProcedures for Opt Out and Removal of Taxpayers from IRS FBAR Voluntary Disclosure Program
Procedures for Opt Out and Removal of Taxpayers from IRS FBAR Voluntary Disclosure Program Guidance for Opt Out and Removal of Taxpayers from the Civil Settlement Structure of the 2009 Offshore Voluntary
More informationRudolph Claus and the Extra-Territorial Enforcement of US. Tax Law. Michael J. Legamaro
Rudolph Claus and the Extra-Territorial Enforcement of US Tax Law Michael J. Legamaro 1 Story of Rudolph Claus Rudolph is a US citizen born in US while Austrian-citizen parents were vacationing He has
More informationINTERNATIONAL TAX CONTROVERSY
INTERNATIONAL TAX CONTROVERSY BY MISHKIN SANTA PETER MITCHELL About Us Who we are What we do Why we re here Part I: International Tax Controversy Voluntary Disclosure Attorney-client privilege IRM 9.5.11.9
More informationCertification of Non-Willfulness Streamlined Filing Compliance Procedure
Certification of Non-Willfulness Streamlined Filing Compliance Procedure Article by: Mishkin Santa, LL.M, J.D. - Director of International Advisory & Legal Services The eligibility requirements for expanded
More informationThe I.R.S. Amnesty Program & The New Streamlined Filing Compliance Procedures
TOPICS IN THE SEMINAR INCLUDE: The I.R.S. Amnesty Program & The New Streamlined Filing Compliance Procedures By Richard S. Lehman, Esq. TAX ATTORNEY www.lehmantaxlaw.com SEMINAR INTRODUCTION by Richard
More informationMoney Laundering and Foreign Bank Accounts
Money Laundering and Foreign Bank Accounts Robert E. McKenzie, EA, Attorney Arnstein & Lehr LLP Robert E. McKenzie 312.876.6927 1 Government Enforcement Money Laundering and BSA Patriot Act Foreign Bank
More informationRadio X June 19 Broadcast Foreign Asset Reporting Questions & Answers
Radio X June 19 Broadcast Foreign Asset Reporting Questions & Answers 1. What is the FBAR filing? FBAR is the acronym for the Foreign Bank Account Report that must be filed annually with the IRS to report
More informationUnited States Attorney Southern District of New York
United States Attorney Southern District of New York FOR IMMEDIATE RELEASE APRIL 15, 2010 CONTACT: U.S. ATTORNEY'S OFFICE YUSILL SCRIBNER, JANICE OH PUBLIC INFORMATION OFFICE (212) 637-2600 IRS JOSEPH
More informationFBAR Foreign Bank Account Reporting
FBAR Foreign Bank Account Reporting ------------------------------------------------------------------------------------------------------------ Form TD F 90-22.1 is required when a U.S. Person has a financial
More informationWhy Tax Evasion Is A Bad Idea: UBS and Wegelin Bank
Why Tax Evasion Is A Bad Idea: UBS and Wegelin Bank Gary S. Wolfe Gary S. Wolfe has been in private practice in Beverly Hills, Century City, and Los Angeles since 1982. He is an international tax lawyer
More informationen T. Mil er Deputy Commissioner for Services and Enforcement
DEPARTMENT OF THE TREASURY INTERNAL REVENUE SERVICE WASHINGTON, D.C. 20224 DEPUTY COMMISSIONER June 1,2011 MEMORANDUM FOR COMMISSIONER, LARGE BUSINESS AND INTERNATIONAL DIVISION COMM SIONER, ~ BUSINESS/SELF-EMPLOYED
More informationIRS Offshore Voluntary Disclosure Program
IRS Launches Third Offshore Voluntary Disclosure Program SUMMARY On January 9, 2012, the Internal Revenue Service (the IRS ) issued a news release announcing that the IRS is opening a third Offshore Voluntary
More informationTax Enforcement Beyond FATCA
Tax Enforcement Beyond FATCA AGENDA Before FATCA Qualified Intermediary Program UBS and the Beginning of the End of Bank Secrecy IRS Offshore Voluntary Disclosure Program Application of U.S. Criminal Law
More informationReporting Cash Transactions and Foreign Financial Accounts (Foreign Bank Account Reports "FBAR")
Reporting Cash Transactions and Foreign Financial Accounts (Foreign Bank Account Reports "FBAR") Form 8300 - Reporting Cash Payments Over $10,000 in a Trade or Business Reportable transactions include,
More informationIT S TIME FOR THE IRS TO MAKE MAJOR CHANGES TO ITS CURRENT OFFSHORE TAX COMPLIANCE OPTIONS
IT S TIME FOR THE IRS TO MAKE MAJOR CHANGES TO ITS CURRENT OFFSHORE TAX COMPLIANCE OPTIONS By Richard A. Josepher, Esq. Gutter Chaves Josepher Rubin Forman Fleisher Miller rjosepher@floridatax.com In August
More informationNAVIGATING VOLUNTARY DISCLOSURE IN THE WAKE OF THE GOVERNMENT S ASSAULT ON UNDISCLOSED FOREIGN ACCOUNTS
NAVIGATING VOLUNTARY DISCLOSURE IN THE WAKE OF THE GOVERNMENT S ASSAULT ON UNDISCLOSED FOREIGN ACCOUNTS Introduction Douglas E. Whitney and Thomas D. Sykes McDermott Will & Emery LLP Chicago, IL A rash
More informationThe Internal Revenue Service (IRS) announced
May 2009 IRS Amnesty to Offshore Tax Evaders The Last, Last Chance? By Ronald A. Marini Ronald Marini explains the IRS s recent announcement of a penalty structure for voluntary disclosures that gives
More informationUS Voluntary Disclosure
what you need to know, and how we can help www.withersworldwide.com Introduction Countries throughout the world have committed to redefining banking secrecy laws so as to no longer protect any form of
More informationAvoid Criminal Prosecution IRS Introduces a Six Month Settlement Initiative For those with Unreported Foreign Accounts
Avoid Criminal Prosecution IRS Introduces a Six Month Settlement Initiative For those with Unreported Foreign Accounts Kevin E. Packman, Holland & Knight LLP EXECUTIVE SUMMARY On March 23, 2009, the IRS
More informationDOJ and IRS Use Carrot n Stick to Enforce Global Tax Laws
DOJ and IRS Use Carrot n Stick to Enforce Global Tax Laws BY JAY R. NANAVATI AND JUSTIN A. THORNTON 4 The US government continues to hammer away at the use by US taxpayers of foreign secrecy jurisdictions
More informationUS Voluntary Disclosure
what you need to know, and how we can help US Voluntary Disclosure what you need to know, and how we can help www.withersworldwide.com www.withersworldwide.com Introduction Countries throughout the world
More informationIRS Penalties: Running Afoul of the Tax Code
IRS Penalties: Running Afoul of the Tax Code The income tax system of the United States is essentially based on the notion of voluntary compliance. You are expected to report and remit the income you ve
More informationHow To Disclose Your Foreign Bank Accounts And Avoid Criminal Prosecution! FIVE STONE. tax advisers
How To Disclose Your Foreign Bank Accounts And Avoid Criminal Prosecution! Do you have or think you may have a foreign bank account that should be disclosed to the United States Government? Have you received
More informationMarch 28, 2012 India Tax Update
Silicon Valley March 28, 2012 India Tax Update Brian br@rowbotham.com (415) 433-1177 www.rowbotham.com U.S. Tax Reporting Challenges IRS Forms Penalties 5471 Foreign Corporation $10k per year per omission
More informationDeadline Looms to Come Clean on Offshore Accounts by Steven J. Mopsick and Betty J. Williams
Deadline Looms to Come Clean on Offshore Accounts by Steven J. Mopsick and Betty J. Williams Date: Sep. 8, 2009 Steven J. Mopsick and Betty J. Williams discuss the impending deadline for taxpayers to voluntarily
More informationReporting Requirements for FBAR: Generally and Under the IRS Amnesty Program
A publication of Kundra & Associates, P.C. Reporting Requirements for FBAR: Generally and Under the IRS Amnesty Program Written by: Chaya Kundra, Esquire & Heather Bravi, Esquire 2009 Kundra & Associates,
More informationWhat s News in Tax Analysis That Matters from Washington National Tax
What s News in Tax Analysis That Matters from Washington National Tax Have Undisclosed Foreign Assets? IRS Offers Options There is good news for individuals who inadvertently failed to fulfill tax and
More informationCross-Border Tax Enforcement Developments and Trends Where Are the U.S. Department of Justice and the IRS Headed?
Cross-Border Tax Enforcement Developments and Trends Where Are the U.S. Department of Justice and the IRS Headed? Steven L. Cantor, Cantor & Webb Daniel W. Levy, McKool Smith February 6, 2015 Trends &
More informationOffshore Tax Evasion: US Initiatives
Scott D. Michel, Caplin & Drysdale This Article discusses the US reporting rules for US taxpayers with foreign accounts and assets (including FBAR and FATCA), the civil penalties for non-compliance with
More informationIRS CRIMINAL INVESTIGATION-AN OVERVIEW
1 IRS CRIMINAL INVESTIGATION-AN OVERVIEW IMF-Japan High Level Tax Conference for Asian and Pacific Countries February 1, 2012 By Richard Speier Jr. Former Deputy Chief IRS CI Outline 2 Legal Provisions
More informationForeign Account Tax Compliance Act ( FATCA ) How Does It Affect NFFEs and Individuals
Foreign Account Tax Compliance Act ( FATCA ) How Does It Affect NFFEs and Individuals May, 2012 2008 Venable LLP 1 agenda Overview FATCA and NFFEs FATCA and Individuals US Information Reporting for US
More informationTax Management International Journal
Tax Management International Journal Reproduced with permission from Tax Management International Journal, 43 TMIJ 604, 10/10/2014. Copyright 2014 by The Bureau of National Affairs, Inc. (800-372- 1033)
More informationBackground of the Foreign Account Tax Compliance Act (FATCA)
1 Background of the Foreign Account Tax Compliance Act (FATCA) The Foreign Account Tax Compliance Act (FATCA) is a U.S. law enacted on March 18, 2010, as part of the Hiring Incentives to Restore Employment
More informationTax Practice and Procedure and SBSE Update
Tax Seminar Baruch College December 3, 2012 Tax Practice and Procedure and SBSE Update Bryan Inoue - Area Director, North Atlantic SBSE, Examination Bryan C. Skarlatos, Kostelanetz & Fink, LLP bskarlatos@kflaw.com
More informationForeign Bank Account Reporting
Foreign Bank Account Reporting and denforcement tupdate: The Internal Revenue Service s 2011 Offshore Voluntary Disclosure Initiative and the New FBAR Regulations Presented by Matthew Lee, Jennifer Bell,
More informationUS Tax Issues for Canadian Residents
US Tax Issues for Canadian Residents SPECIAL REPORT US Tax Issues for Canadian Residents The IRS has recently declared new catch up filing procedures for non-resident US taxpayers who are considered innocent
More informationIRS Renews Its Focus on Unreported Foreign Accounts and Assets: The 2011 Disclosure Program
Checkpoint Contents Tax News Journal Preview (WG&L) Journal of Taxation IRS Renews Its Focus on Unreported Foreign Accounts and Assets: The 2011 Disclosure Program, Journal of Taxation FRAUD & NEGLIGENCE
More informationCorrective U.S. Tax Compliance for Dual Status and Foreign Taxpayers Andrew Bernknopf, Esq., Member:
Corrective U.S. Tax Compliance for Dual Status and Foreign Taxpayers Andrew Bernknopf, Esq., Member: This article provides an overview of corrective United States tax compliance measures for individuals
More informationPractical Tips and Tricks for FBAR Compliance: A Hands-on Guide for Navigating the FBAR Reporting Regime
Practical Tips and Tricks for FBAR Compliance: A Hands-on Guide for Navigating the FBAR Reporting Regime Deidra W. Hubenak, JD, CPA Austin C. Carlson, JD 2011 Looper Reed & McGraw, P.C. The information
More informationUniversity of Illinois Tax School 2014 Federal Tax Workbook Chapter 6: IRS Representation and Procedures
University of Illinois Tax School 2014 Federal Tax Workbook Chapter 6: IRS Representation and Procedures Presenter s Name: Shawn Savage IRS Sr. Stakeholder Liaison Date: October 21, 23, 29 2014 Topic 1:
More informationCase 1:10-cr-20878-JLK Document 62 Entered on FLSD Docket 11/10/2011 Page 1 of 9
Case 1:10-cr-20878-JLK Document 62 Entered on FLSD Docket 11/10/2011 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. I O-20878-CR-KING UNITED STATES OF AMERICA v. RENZO GADOLA,
More informationHow To Get A Summons From The Irs On Ubs Ag
SETTLEMENT AGREEMENT WHEREAS, The United States of America (the United States ), the U.S. Internal Revenue Service ( IRS ) and UBS AG ( UBS ) (singularly a Party and collectively the Parties ) desire to
More informationPARALLEL IRS INVESTIGATIONS: A WOLF IN LAMB S CLOTHING?
PARALLEL IRS INVESTIGATIONS: A WOLF IN LAMB S CLOTHING? By Howard L. Richshafer, Esq. I. Background. A. 34 years ago, a major federal appeals court was outraged by IRS conduct. This is the infamous Tweel
More informationTHE IRS RACE FOR INTERNATIONAL TAX COMPLIANCE
Today s session THE IRS RACE FOR INTERNATIONAL TAX COMPLIANCE Wednesday, March 27, 2013 1:00 to 2:30 pm EST Speakers Steve Waserstein, Partner, WNF Law, P.L. Waserstein Nunez & Foodman Daniel Foodman,
More information10/29/2012. In any professional service, a member shall maintain objectivity and integrity, shall be free from conflicts of interest.
Jonathan E. Strouse Holland & Knight LLP 131 S. Dearborn, 30th Floor Chicago, IL 60603 312-715-5741 jonathan.strouse@hklaw.com 1 1. Introduction 2. (No Circular 230 Discussion) 3. ET Section 102 and Interpretation
More informationOffshore#Banking#and#Foreign#Bank#Accounts: Keeping#your#Clients#out#of#Trouble#with#the#IRS
Moving#Your#Practice#in#the#Right#Direction# TM Offshore#Banking#and#Foreign#Bank#Accounts: Keeping#your#Clients#out#of#Trouble#with#the#IRS A"Practice"Essentials"Presentation #2011#OnePath#Practice#Management#Advisors,#LLC.#All#Rights#Reserved.
More informationAmerican Bar Association Section of Family Law 2014 Spring CLE Conference PLENARY:
American Bar Association Section of Family Law 2014 Spring CLE Conference PLENARY: How to Find Your Spouse s Secret Offshore Bank Account: Using U.S. Tax Reporting Requirements as a Discovery Tool for
More informationCONSIDERATIONS AND STRATEGIES WHEN THE TAXPAYER IS ALREADY IN TROUBLE
CONSIDERATIONS AND STRATEGIES WHEN THE TAXPAYER IS ALREADY IN TROUBLE By Leslie Shields Attorney at Law The Shields Law Firm, P.L.L.C. 402 S. Northshore Drive Knoxville, Tennessee 37919 Phone (865) 546-2400
More informationIRS Targets Offshore Bank Accounts: Taxpayers Need Professional Guidance on Quick, Complete Disclosure
IRS Targets Offshore Bank Accounts: Taxpayers Need Professional Guidance on Quick, Complete Disclosure David Gannaway The author believes that disclosure of offshore accounts can be handled with discretion
More informationBritish boy marries American
British boy marries American girl! An Americanʼs Reporting Responsibility! The USA imposes personal income taxes based on the principle citizenship taxation under which all citizens of the United States
More informationIRS considers new partial amnesty program for offshore accounts: strategic considerations for taxpayers
1/28/2011 Page 1 of 5 IRS considers new partial amnesty program for offshore accounts: strategic considerations for taxpayers Morrison & Foerster LLP Joseph Fletcher, Eugene Illovsky and Edward L. Froelich
More informationState of California Department of Corporations
STATE OF CALIFORNIA BUSINESS, TRANSPORTATION AND HOUSING AGENCY DEPARTMENT OF CORPORATIONS Allied Cash Advance California, LLC dba Allied Cash Advance File # 0- and 0 locations NW th Street, Suite 00 Doral,
More informationCONSENT ORDER PURSUANT TO BANKING LAW 44-a. The New York State Department offinancial Services ("the Department") and Credit
NEW YORK STATE DEPARTMENT OF FINANCIAL SERVICES CONSENT ORDER PURSUANT TO BANKING LAW 44-a The New York State Department offinancial Services ("the Department") and Credit Suisse stipulate that: WHEREAS
More informationForeign Accounts and IRS Tax Implications
What to Do When a Client Has an Un isclosed Foreign Account Weighing the options requires a thorough understanding of risks. by Scott H. Novak, Esq. \ C PAs often have clients with an interest in or signature
More informationDon't go it alone* The IRS collection process. pwc. *connectedthinking. Introduction. IRS emphasis on increasing tax collection.
IRS Service Team Don't go it alone* The IRS collection process Introduction Taxpayers periodically request assistance with IRS collection matters. IRS collection contacts can appear intimidating, and taxpayers
More informationOliver Biernat ITPG Global Chairman
Oliver Biernat ITPG Global Chairman ITPG-Meeting, GGI North American Conference, New Orleans, 15 May 2014 Introduction What do you know about the Hoeneß case? (1) Swiss and Luxemburg banks urge their clients
More informationCALIFORNIA STATE BAR TAXATION SECTION TAX PROCEDURE AND LITIGATION COMMITTEE AND INTERNATIONAL TAX COMMITTEE
CALIFORNIA STATE BAR TAXATION SECTION TAX PROCEDURE AND LITIGATION COMMITTEE AND INTERNATIONAL TAX COMMITTEE A SIMPLIFIED PROCEDURE TO ALLOW LATE FILED FORMS 8891 FOR INDIVIDUALS WITH CANADIAN RETIREMENT
More informationCan IRS Be Trusted? A Troubling New Development in the Offshore Voluntary Disclosure Program
Checkpoint Contents Federal Library Federal Editorial Materials WG&L Journals Journal of Taxation (WG&L) Journal of Taxation 2013 Volume 118, Number 04, April 2013 Articles Can IRS Be Trusted? A Troubling
More informationDispelling Fear! What are your fears?! - Criminal implications! - Cost of penalties! - Cost of getting compliant with advisors!
Dispelling Fear! What are your fears?! - Criminal implications! - Cost of penalties! - Cost of getting compliant with advisors! Do not fear the consequences, get the facts:! Each Individual is unique!
More informationFiscal Year 2011 Report to the Congress on the Use of Section 7623
Fiscal Year 2011 Report to the Congress on the Use of Section 7623 Table of Contents I. Executive Summary... 1 II. Program History... 2 A. Prior Law and Policy... 2 B. 2006 Amendments... 3 C. Implementing
More informationMay 7, 2012 California Bar Suggests Guidance, Safe Harbor to Aid Foreign Pension Beneficiaries
May 7, 2012 California Bar Suggests Guidance, Safe Harbor to Aid Foreign Pension Beneficiaries Philip D.W. Hodgen and Steven L. Walker of the California State Bar Taxation Section proposed that the IRS
More informationFiscal Year 2013 Report to the Congress on the Use of Section 7623
Fiscal Year 2013 Report to the Congress on the Use of Section 7623 Table of Contents I. Executive Summary... 1 II. Program History... 2 A. Prior Law and Policy... 2 B. 2006 Amendments... 3 III. Program
More informationIRS Offshore Voluntary Disclosure Initiative Round Two
View this email as a webpage. February 2011 www.ssd.com IRS Offshore Voluntary Disclosure Initiative Round Two On February 8, 2011 the US Internal Revenue Service (the IRS) announced its second, much anticipated,
More informationAre You Ready For New Form 8938 to Report Specified Foreign Financial Assets?
Are You Ready For New Form 8938 to Report Specified Foreign Financial Assets? The Hiring Incentives to Restore Employment ( HIRE ) Act, signed into law in 2010, included modified provisions of the previously
More informationThe IRS Approach to Retroactive Relief for VDP Taxpayers
The IRS Approach to Retroactive Relief for VDP Taxpayers Introduction By Allen J. Littman and Michael W. Nydegger Allen J. Littman is a tax partner in the Washington office of Baker & Hostetler LLP. Michael
More informationExamination Representation 101
Examination Representation 101 IRS Operating Divisions Wage and Investment Division (W & I) Tax Exempt / Governmental Entities (TEGE) Small Business / Self-Employed (SB/SE) Large Business and International
More informationInternational Trade and Government Regulation practice in the Washington, DC office of Dechert LLP.
FCPA Enforcement: 2015 Highlights and Trends By: Jeremy Zucker, Darshak Dholakia, and Hrishikesh Hari 1 With record settlements, continued aggressive enforcement, a renewed focus on prosecuting individuals,
More informationIMPACT. May/June 2014. Capturing the benefits of captive insurance. How defined-value gifts can help limit your tax exposure
tax May/June 2014 IMPACT Capturing the benefits of captive insurance How defined-value gifts can help limit your tax exposure Undisclosed foreign accounts: Handle with care Tax Tips Hire your kids to save
More informationThe Life Cycle of an IRS Audit
The Life Cycle of an IRS Audit By Robert M. Finkel and Diana C. Española mbbp.com Business Technology & IP Employment & Immigration Taxation 781-622-5930 Reservoir Place 1601 Trapelo Road, Suite 205 Waltham,
More informationIncreased IRS Tax Compliance Involving U.S. Citizens/Green Card Holders in Israel
Increased IRS Tax Compliance Involving U.S. Citizens/Green Card Holders in Israel October 2012 Tax Seminar Stuart M. Schabes, Esquire Ober, Kaler, Grimes & Shriver smschabes@ober.com 410-347-7696 (U.S.)
More informationDaniel W. Levy! Presentation to Society of Trust and Estate Practitioners! Miami, Florida
Daniel W. Levy Presentation to Society of Trust and Estate Practitioners Miami, Florida May 30, 2014 Austin Dallas Houston Los Angeles Marshall New York Silicon Valley Washington, DC Department of Justice
More informationForeign Financial Account & Asset Reporting: FinCen (FBAR) v. FATCA
Foreign Financial Account & Asset Reporting: FinCen (FBAR) v. FATCA Presented by David J Lewis, Attorney, of Krugliak, Wilkins, Griffiths & Dougherty Co. LPA and Patricia L Gibbs, CPA, of CBIZ MHM September
More informationPresented By Greg Baldwin
ANTI-MONEY LAUNDERING COMPLIANCE OFFICER TRAINING Presented By Greg Baldwin THE ANTI-MONEY LAUNDERING COMPLIANCE OFFICER We re going to cover: Basis for the requirement to have a Compliance Officer The
More informationIMPACT. May/June 2014. Capturing the benefits of captive insurance. How defined-value gifts can help limit your tax exposure
tax May/June 2014 IMPACT Capturing the benefits of captive insurance How defined-value gifts can help limit your tax exposure Undisclosed foreign accounts: Handle with care Tax Tips Hire your kids to save
More informationIRS Administrative Appeals Process Procedures
IRS Administrative Appeals Process Procedures Charles P. Rettig Avoiding litigation is often the best choice for a client. The Administrative Appeals process can make it happen. Charles P. Rettig, a partner
More informationHKMA Seminar Tax Evasion in Hong Kong. 30 October 2013
HKMA Seminar Tax Evasion in Hong Kong 30 October 2013 Contents - Control environment and risk mitigation Know Your Customer 3 Voluntary Tax Compliance 5 Tax Evasion Red Flags 6 Suggested Approaches 9 Case
More informationHC 677 SesSIon 2010 2011 17 December 2010. HM Revenue & Customs. Managing civil tax investigations
Report by the Comptroller and Auditor General HC 677 SesSIon 2010 2011 17 December 2010 HM Revenue & Customs Managing civil tax investigations 4 Summary Managing civil tax investigations Summary 1 In 2009-10,
More informationTHE HIGH COURT REVENUE 2009 No. MCA
THE HIGH COURT REVENUE 2009 No. MCA IN THE MATTER OF SECTION 908 OF THE TAXES CONSOLIDATION ACT 1997 (AS SUBSTITUTED BY SECTION 207(I) OF THE FINANCE ACT, 1999) BETWEEN: Principal Officer (Name redacted)
More informationReport of Foreign Bank and Financial Accounts (FBAR)
Report of Foreign Bank and Financial Accounts (FBAR) Presenter s name Date Objectives FBAR purpose FBAR reporting / recordkeeping FBAR penalties Compliance initiatives 2 FBAR Purpose Combat the use of
More informationPresented By: VCSP Overview. Introduction. Who is Eligible for the VCSP? VCSP Eligibility
From Both Sides of the Table: Analyzing the IRS' New Worker Classification Settlement Initiative Presented By: ANITA F. BARTELS Internal Revenue Service SB/SE Employment Tax ANTHONY P. DADDINO Tax Partner
More information2015 TAX COURT JUDICIAL CONFERENCE
2015 TAX COURT JUDICIAL CONFERENCE CONFLICTS AND CHAOS: THE IMPORTANCE OF TIMELY RECOGNIZING AND MANAGING CONFLICTS OF INTEREST AND RELATED PROBLEMS IN TAX LITIGATION Discussion Hypotheticals May 22, 2015
More informationIRS & THE FBAR: International Focus For U.S. Tax Compliance
IRS & THE FBAR: International Focus For U.S. Tax Compliance INTRODUCTION By Sandra R. Brown i While the laws dealing with the disclosure of foreign bank or financial accounts took effect in 1970, nearly
More information