This Saturday, October 15th, marks the extended deadline to file your annual Report of Foreign Bank and Financial Accounts (FBAR)! If you have a financial interest or authority over any financial account located outside of the United States, and at any time during...
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U.S. Supreme Court Grants Certiorari in a Tax Case
Taxpayers with significant FBAR non-willful penalties may breathe a sigh of financial relief if the U.S. Supreme Court decides the FBAR non-willful penalty is per form, not per account. Yesterday, the U.S. Supreme Court granted certiorari in Bittner, Alexandru v. U.S....
South Dakota – the New Switzerland for Bank Secrecy?
Switzerland, Singapore, and South Dakota all have something in common…these jurisdictions are favored by the extremely wealthy for bank secrecy, which often includes tax evasion, money laundering, and other crimes including worker exploitation. In 2014, Trident Trust...
Joint Chiefs of Global Tax Enforcement Report on Progress Identifying Massive Global Tax Cheats
It has been two years since international tax leaders from Australia, Canada, the Netherlands, the United Kingdom, and the United States joined forces in the “J5” to combine resources to target enablers of tax crime, particularly related to virtual currency. Since its...
Swiss Banks Pay Big Penalties for Failure to Disclose U.S. Accounts
The Department of Justice recently imposed another $5.3 million penalty on Bank Lombard Odier & Co., Ltd., a Swiss bank that has already paid over $99 million for offering offshore banking services to U.S. taxpayers without disclosing their transactions. Since...
Did You Withdraw Your IRS Offshore Voluntary Disclosure? You May Get Audited!
The IRS Large Business and International division (LB&I) is rolling out a series of campaigns focused on specific compliance issues. The division analyzed extensive data as well as suggestions from IRS compliance employees and the tax community to improve large...
Montenegro Agrees to Implement FATCA Provisions
On June 1, 2017, U.S. Ambassador Margaret Ann Uyehara and Montenegrin Finance Minister Darko Radunovic signed an Intergovernmental Agreement (IGA) to combat offshore tax evasion by implementing the provisions of the Foreign Account Tax Compliance Act (FATCA). Banks...
TIGTA Recommends Changes To Offshore Account Disclosure Programs
The Internal Revenue Service (IRS) may begin ramping up its investigation of offshore account compliance soon, based on recommendations from the Treasury Inspector General for Tax Administration (TIGTA). TIGTA recently released its final report on the IRS' offshore...
What the Panama Papers Leak Means for You
If you have offshore assets that are not yet properly disclosed, you should consider contacting an attorney immediately for assistance, before a civil or criminal investigation begins. On April 3, 2016, the International Consortium of Investigative Journalists (ICIJ),...
Video: Benefit from our experience in offshore voluntary disclosures
Individuals and businesses often take advantage of the benefits offshore banking provides. You may have opened an account to ensure that you get to keep more of your hard-earned money with a favorable tax rate. You may have used a trust or foundation to protect your...
