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 […]
Category: Articles
In a case that has raised eyebrows in the tax community, a jury in the Southern District of Florida has sustained the IRS’s assessment of multiple willful FBAR penalties against an American business man and bank director. Carl Zwerner, an 87 year-old man born in Yonkers, New York, started a […]
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 […]
Many companies hire independent contractors for limited projects to reduce overall costs. Companies do not withhold income, Social Security or Medicare taxes for independent contractors and do not provide the same benefits generally offered to regular employees. It becomes the contractors’ responsibility to pay their own self-employment taxes and benefits. […]
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 […]
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 […]
The Justice Department’s Tax Division has continued its aggressive mission to obtain bank record information on U.S. citizen’s offshore accounts. As they describe it, the “top litigation priority is the concerted civil and criminal effort to combat the serious problem of non-compliance with our tax laws by U.S. taxpayers using […]
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 […]
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, […]
To use a basketball analogy, the IRS is increasingly putting on the full-court press when it comes to collecting money from Americans with offshore accounts. This article will discuss how the IRS may use the Foreign Tax Compliance Act (FATCA) to turn up the pressure on Americans with foreign bank […]