Due Diligence
Posts Tagged OVDI attorney
The Hunt Is On – IRS Targets Caribbean Bank For Offshore Accounts
by Brian Mahany The IRS is looking for unreported offshore accounts worldwide. This week, the IRS obtained a John Doe subpoena from a federal court allowing authorities to search for records from Canadian Imperial Bank of Commerce’s FirstCaribbean International Bank (FCIB). Previous IRS enforcement efforts have been targeted at banks in Switzerland, Israel and India. [...]
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Worried About OVDI / OVDP Penalties? Don’t! Payment Options Are Available
by Brian Mahany We frequently encounter absolute shock when we tell prospective clients about the potential penalties for an unreported foreign account. Miss filing an FBAR (that’s Treasury jargon for the Report of Foreign Bank and Financial Account also known as a TD F 90-22.1 form) for just 1 year and the penalty can be [...]
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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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IRS Gets Copies Of Adviser’s US CLient List – FBAR Post
Posted by admin in Tax, White Collar Criminal on March 16, 2013
by Brian Mahany We are still scratching our heads over this story. A Swiss financial planner / CPA “accidentally” mailed his client list. Now the list is in the hands of Uncle Sam. According to published reports, 3 of his clients have already been charged by federal prosecutors for having unreported foreign accounts. Sooner or [...]
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OVDI – It’s Not Just For Unreported Foreign Accounts
by Brian Mahany Although 99% of the people that contact us about the IRS’ Offshore Voluntary Disclosure Program (called “OVDI” or “OVDP”) have unreported foreign accounts, the program can be used to come into compliance with other foreign reporting problems. The program can be used for people with unreported foreign entities and for people who have [...]
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Taxpayer Advocate Questions OVDI, FBAR Penalties
by Brian Mahany Every year, the National Taxpayer Advocate issues a report to Congress. In it she discusses her own independent findings and makes recommendations on how the agency should be reformed. Although a IRS employee, NTA Nina Olson is really independent of the agency and has the ability to report directly to Congress without [...]
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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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Two More Taxpayers Sentenced For Unreported Foreign Accounts
by Brian Mahany The feds are on a roll. Two more Americans have been sentenced for failure to report foreign bank accounts. According to press releases and court documents, Miami Beach resident Luis Quintero was sentenced to 4 months in prison and given $2,020,000 in fines and penalties. Miami Lakes resident Humberto Gomez received 3 [...]
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How To Beat FBAR Penalties!
by Brian Mahany I received an interesting call today from someone concerned about the IRS penalties for failure to file a Report of Foreign Bank and Financial Accounts, better known as an FBAR (TDF-90-22.1 for those looking for the IRS form number). For those not already aware of the penalties, the IRS can and routinely [...]
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OVDP Penalties – 27.5%? 12.5%? 5%?
by Brian Mahany Folks not familiar with the current IRS tax amnesty program for unreported offshore accounts are often confused about how much in penalties will be collected if they successfully enter the program. Assuming one qualifies, the program has a three tiered penalty system. Before discussing the penalties, some history of the program is [...]
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