If you have been a regular reader of our tax and corporate articles, it has been hard not to notice the IRS targeting banks and financial institutions more and more frequently in connection with disclosure of unreported offshore bank accounts and unreported income.
Bank Leumi, Bank Hapoalim, several Swiss banks, and others have been in the news with IRS scrutiny on their disclosing the names of their U.S. depositors. In addition, the list of countries signing onto FATCA (the mutual assistance of offshore foreign governments forcing their financial institutions to disclose the names of their U.S. account holders) continues to grow.
This week, Wells Fargo N.A. and the Canadian Imperial Bank of Commerce First Caribbean International Bank (FCIB) are in the news. As part of an effort billed as international tax enforcement, the IRS successfully obtained authorization of the Federal District Court in San Francisco to serve what’s known as John Doe Summonses on Wells Fargo N.A. to obtain information about their U.S. account holders which includes information about money deposited, money paid out through checks and money moved by wire transfers. Wells Fargo provides correspondent services to FCIB, which operates in several Caribbean countries.
As we have said in the past, secret bank accounts are becoming dinosaurs. If you are a depositor in any of these financial institutions and have “issues” regarding disclosure of Offshore Foreign Bank Accounts, then you have even more reason to seek the advice of tax professionals to satisfactorily resolve those issues.
For more information on the IRS Offshore Voluntary Disclosure Program (OVDP), offshore reporting matters, or other tax law concerns, contact Horowitz Law Offices.