Offshore Disclosure — The Options

For the last several years, the IRS has made a concerted push to crackdown on undisclosed offshore accounts and foreign assets.  The bottom line is of course to recover unpaid taxes.  These efforts have been strengthened recently by agreements reached between the IRS and offshore financial institutions and governments.  These agreements largely stem out of…

Swiss Banks Receive Fresh Round of Information Requests

The US Department of Justice has sent information requests to forty Swiss banks taking part in an information sharing program between the US and Switzerland.  This program evolved out of the 2010 Foreign Account Tax Compliance Act (FATCA) which provides from automatic information sharing between foreign financial institutions and the US government regarding the accounts…

IRS Crackdown Expands With New Penalty For Banks

Today a key provision of the Foreign Account Tax Compliance Act (FATCA) goes into effect.  The 2010 law aims to combat tax evasion accomplished through offshore accounts by setting up information sharing agreements between the IRS and foreign financial institutions or foreign governments.  To date more than 80 jurisdictions have reached such agreements with the…

IRS Accelerates Attack on Foreign Offshore Bank Accounts

Hardly a day passes when we do not hear of yet another country entering agreements with the IRS that have the effect of requiring financial institutions in those countries to make various disclosures to the IRS regarding U.S. taxpayers’  offshore bank accounts. Recently there have been announcements regarding Barclay’s private bank in Switzerland.  Last week,…

Quiet Disclosures Are Making A Lot of Noise

Since the onset of the original Offshore Voluntary Disclosure Initiative (OVDI) in 2009 and its successor Offshore Voluntary Disclosure Program (OVDP) and subsequent progeny programs, taxpayers with undisclosed offshore accounts or foreign accounts have for the most part been able to avoid criminal prosecution at the expense of paying fines for failing to disclose and…

Offshore Account Reporting – Bank Leumi, Bank Hapoalim, Mizrahi Tefahot Bank Accused of Adding A Twist

According to various reports the IRS is investigating the Israeli banks Bank Leumi, Bank Hapoalim and Mizrahi Tefahot Bank for conspiring with individuals to enter into a loan scheme intended to evade taxes on funds brought to the U.S. from undisclosed foreign bank accounts.  The focus on the banks themselves is a notable departure from…

2011 OVDI Deadline Extended

Because of Hurricane Irene, the IRS has decided to extend the application deadline for the 2011 Offshore Voluntary Disclosure Initiative to September 9th.  The deadline had previously been August 31.  This extension also applies to Report of Foreign Bank and Financial Accounts (FBAR) forms. The OVDI is a tax amnesty initiative by which taxpayers with…