I receive many inquiries about Streamlined Filings from U.S. citizens or Green Card holders living outside the U.S. as well as from recent immigrants to the U.S. or work visa holders living inside the U.S. In all of these...
Category: OFFSHORE BANK ACCOUNTS
IRS NOOSE TIGHTENS ON THOSE WITH UNREPORTED OFFSHORE ACCOUNTS: CARIBBEAN AND AUSTRALIAN ACCOUNT HOLDERS AT GREAT RISK
September 30, 2015
The IRS continues to cast a wider net for offshore tax cheats and continues to make the cost of waiting to come into compliance expensive. Some recent developments illustrate: Tax storm in the Caribbean: The IRS had...
The Department of Justice (DOJ) on May 29, 2015 announced that four more Swiss banks had entered into non-prosecution agreements (NPA), namely: Societe Generale Private Banking (Lugano-Svizzera) SA (effective 5/28/15)...
IRS OFFICIALS ANSWER CIVIL AND CRIMINAL OFFSHORE QUESTIONS
February 26, 2015
On February 24, 2015 I participated in an ABA Tax Section Webinar, “Answering Your Criminal and Civil Offshore Disclosure Questions.” On the Webinar panel were two IRS officials: David W. Horton, Director, IRS...
OFFSHORE VOLUNTARY DISCLOSURE PROGRAM (OVDP): STRICT APPLICATION OF 50% PENALTY CAN BE HARSH
February 15, 2015
Consider the following fact pattern: Father and daughter are participants in the OVDP who submitted their OVDP Letters after August 4, 2014. Each owned separate unreported offshore bank accounts during the OVDP period...