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Category: Articles

U.S. to Ease Initial Enforcement of FATCA

With FATCA set to take effect on July 1, financial institutions around the world have been lobbying to delay implementation of the law, citing concerns about costs and potential disruptions to global markets. Over the weekend of May 3rd, the Treasury Department announced that it would not strictly enforce many […]


The Shifting Landscape of the OVDP Opt-Out

Since the IRS announced the 2009 Offshore Voluntary Disclosure Program (OVDP) over five years ago, our firm has been assisting taxpayers submit accurate and complete disclosures in accordance with the program guidelines and procedures. The evolution of the OVDP through the 2011 and 2012 programs has brought a longer look-back […]


The FATCA: Newest Example of American Imperialism

As part of the 2010 Hiring Incentives to Restore Employment (HIRE) Act, the authority of the Internal Revenue Service (IRS) will soon reach across international borders to tax or fine foreign financial institutions (FFIs) and non-financial foreign entities (NFFEs). The FATCA Makes FFIs and NFFEs Do the IRS’s Dirty Work […]


The 2011 IRS Offshore Voluntary Disclosure Initiative

In February 2011, the IRS announced its 2011 Offshore Voluntary Disclosure Initiative (OVDI), a program that would allow those with offshore assets who had not previously declared and paid taxes on them to become current in their tax obligations. Motivated by the success of past disclosure programs and the need […]


Second Special Voluntary Disclosure Initiative

The IRS announced on February 8, 2011, a second voluntary initiative inviting taxpayers with hidden offshore assets to come forward. This initiative is intended to help people get current with their taxes related to offshore assets and will remain in place until August 31, 2011. Participants may face penalties ranging […]


Offshore Accounts in Government Crosshairs

As the U.S. government looks for increased revenue, one of the most attractive places to look is where taxes that should be paid have not been paid. Since the 2009 voluntary disclosure initiative, which was very successful, and since recent legislative and policy changes of foreign governments such as Switzerland, […]