Due Diligence
Posts Tagged California OVDI lawyer
OVDI Offshore Amnesty “Opt Outs” A Good Deal?
by Brian Mahany Spend an hour on the Internet and you will find many self-proclaimed experts suggesting the best way to come into compliance with the IRS offshore reporting rules and avoid steep penalties. Several theories abound including “quiet disclosures”, “opt outs,” “noisy disclosure” and going the amnesty route which involves a one time 27.5% [...]
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What Cyprus Meltdown Means For Offshore Account Holders (OVDI Post)
by Brian Mahany Immediately after posting a story about Cyprus’ ill fated plan to tax bank accounts, the Wall Street journal ran a story about Russians “rethinking” offshore accounts in there. We are not surprised. People invest and open foreign bank accounts because they want to keep their hard earned money safe, not see it [...]
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HSBC Argentina Charged In Tax Fraud Case
by Brian Mahany HSBC always seems to be in the news these days. And it isn’t good news. Money laundering, helping Americans evade taxes and even helping narcoterrorists. Today’s news doesn’t come from Uncle Sam, however, it comes from AFIP, Argentina’s Revenue Service. The Argentines criminally charged HSBC Bank Argentina with evading taxes and money [...]
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IRS Begins Rejecting OVDI Filings – Important News For Fence Sitters
by Brian Mahany We have written at least 100 posts about the Offshore Voluntary Disclosure Program (called OVDI or OVDP) and the need to file FBARs (Reports of Foreign Bank and Financial Accounts). In almost every such post we remind readers that time is running out. Many folks learned this week just how true that [...]
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Death, Taxes and Swiss Bank Accounts (FBAR Post)
by Brian Mahany If you look up In Re Various Grand Jury Subpoenas in the Manhattan federal court’s docket, you won’t find much. Everything is sealed. Everything except Judge William Pauley’s order dated February 19th. In an unusually harsh opinion, Judge Pauley had nothing kind to say about Americans with unreported foreign accounts. The IRS [...]
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South Africa Newest Country To Begin FATCA Dialogue With US – FATCA / FBAR Post
by Brian Mahany All the FATCA news this month has been about Switzerland. Even we got in on the action after the Swiss finance ministry signed a FATCA agreement with the United States. FATCA is short for the Foreign Account Tax Compliance Act, a law recently passed by Congress that requires foreign banks to share [...]
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Switzerland Inks Disclosure Agreement With IRS – FATCA Post
by Brian Mahany Ever since the Department of Justice brought criminal charges against Swiss banking giant UBS, we have speculated on when Switzerland’s reputation for banking secrecy would finally fall. Over the last few years, the IRS and DOJ have teamed up to prosecute several Swiss bankers and their clients – Americans with unreported foreign [...]
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Court Approves IRS “John Doe” Summons For Unreported Swiss Account Records
by Brian Mahany With the ink barely dry on Swiss private bank Wegelin’s guilty plea to criminal tax charges, a U.S. District Court judge today approved a summons for customer records from UBS. The IRS wants the records to identify Americans and other U.S. taxpayers with unreported foreign accounts. Although owning or controlling a Swiss [...]
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Mexico, U.S. Sign FATCA Accord
by Brian Mahany The United States Treasury Department has negotiated or is close to signing deals with over 50 foreign countries. Congress enacted the Foreign Account Tax Compliance Act (FATCA) two years ago. That law already requires individuals to report interests in foreign financial assets. (Don’t forget that U.S. taxpayers also have an independent obligation [...]
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Think No One Will Discover Your Offshore Account? Read This!
by Brian Mahany We are never surprised anymore when the feds announce a new wave of indictments against taxpayers with unreported accounts. Until 2008, the IRS didn’t look very hard and prosecutions were few. As the economy has soured, tax authorities around the world have become quite creative in finding new revenue streams. To enforce [...]
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