Early this year, the United States Government Accountability Office (GAO) identified an area of tax evasion the IRS may have missed. Specifically, taxpayers with undisclosed offshore accounts who have attempted to come into compliance quietly, and not through one of...
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International Tax Law
Disproportionate Penalties for FBAR Non-Filers
In the National Taxpayer Advocate's 2012 Report to Congress, it issued data highlighting the disproportionate penalties to account holders with undisclosed offshore accounts who participate in the IRS' Offshore Voluntary Disclosure Program (OVDP). Generally, if a...
Express Delivery FBAR Address and Mandatory Electronic Filing of FBAR Forms
As you likely are aware, FBARs are due June 30th, which is a date that cannot be extended, even when June 30th is on a weekend, as it is this year. Therefore, FBARs are due to be received by the Department of the Treasury in Detroit, Michigan, by Friday, June 28th. On...
Willful Failure to File an FBAR Penalty is 50% Per Year
The U.S. is seeking to recover 50% of the account balance for each of the four years taxpayers willfully failed to file an FBAR report in United States v. Zwerner (SD FL No. 13-cv-22082-CMA). The U.S. asserts the Zwerner's hid between approximately $723,000 and...
Mexican Land Trust arrangements deemed not to be Trusts under Treasury Regulation section 301.7701-4(a)
Revenue Ruling 2013-14 describes a typical Mexican Land Trust (MLT), or fideicomiso, and concludes that the arrangement is not a trust within the meaning of § 301.7704-4(a).
IRS Closes In On Secret Caribbean Accounts
The IRS is continuing to crack down on undisclosed foreign accounts. One common location for offshore accounts - the Caribbean - is now facing increasing scrutiny by the IRS.To read more, click here.
Luxembourg Agrees to Share Information with the U.S.
Luxembourg has recently agreed to enter into the Model I FATCA Agreement, which provides for an automatic exchange of information between the Luxembourg and American fiscal authorities on bank accounts held in Luxembourg by citizens and residents of the United...
IRS Reminds Those with Foreign Assets of U.S. Tax Obligations
Remember that FBAR reports are due for clients on June 28th, since there are no filing extensions on FBARs and the due date of June 30th falls on a Sunday this year. The filing deadline of June 15th for U.S. citizens and resident aliens living overseas or serving in...
IRS, Australia and United Kingdom Engaged in Cooperative Effort to Combat Offshore Tax Evasion
The tax administrations from the United States, Australia and the United Kingdom announced today a plan to share tax information involving a multitude of trusts and companies holding assets on behalf of residents in jurisdictions throughout the world.The three nations...
Federal Court in San Francisco Authorizes Service of John Doe Summons on Wells Fargo Seeking the Identities of U.S. Taxpayers with Offshore Accounts
A federal court in San Francisco authorized the Internal Revenue Service (IRS) to serve a John Doe Summons seeking information about U.S. taxpayers who hold correspondent accounts at Wells Fargo for Canadian Imperial Bank of Commerce's FirstCaribbean International...