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A strange story involving a Canadian baby who also has U.S. citizenship, her bank, the Canadian Revenue Agency and the IRS raises legal issues that will be important to other U.S. citizens living in Canada (and in other countries) with (and without) dual citizenship. iPolitics reported in April that a […]
Category: Offshore Accounts/International Tax Disputes
Most people only remember April 15 when thinking about taxes. For those with an aggregate interest of at least $10,000 in foreign accounts, June 30 is another date to remember for one more year. It is the filing deadline for Form 114, Report of Foreign Bank and Financial Accounts […]
For over seven years, U.S. authorities have been cracking down aggressively on unreported offshore accounts. The crackdown has proceeded on multiple levels, across continents, with surprisingly effective results. A key moment came in 2009, when the Swiss banking giant UBS agreed to pay $780 million to resolve allegations by the […]
Two years ago, former billionaire Sam Wyly lost a fraud trial in New York that exposed a web of offshore entities that were used to shelter millions of dollars. After the 2014 verdict, the IRS entered the fray seeking $1.4 billion in back taxes. Penalties and interest accounted for 80 […]
Have you recently moved from China or India to the United States for a new career opportunity? Are you an American living abroad? You need to report all foreign bank accounts, if at any point in the 2015 the aggregate value of your accounts exceeded $10,000. Failing to report overseas […]
The global media has about exhausted the number of angles they can report on the so-called “Panama Papers.” The leak has become synonymous with using offshore accounts and companies to avoid tax obligations. Offshore accounts have been in and out of the news. The prosecution of Swiss bank giant UBS […]
One way is prosecuting banks that have allegedly helped taxpayers avoid their U.S. tax liabilities. For instance, the Swiss Bank Program required banks to pay hefty fines and disclose information on accounts held by U.S. persons as part of non-prosecution agreements. Whistleblowers are another. Since 1867, the Treasury Secretary has […]
April 15 has become synonymous with tax day in the United States. This year is a little different, because the Internal Revenue Service is celebrating Emancipation Day. Public employees in Washington D.C. get the day off or the closest day when the April 16th holiday falls on a weekend. As […]
The best answer we can provide is probably not. If you owe a significant tax debt, your passport could soon be in jeopardy. A provision in the FAST Act granted the Internal Revenue Service another tax collection tool: the ability to revoke, deny or limit passports. The law requires the […]
For the past decade U.S. government investigators have been ferreting out hidden financial accounts across the world. Much has been written about Department of Justice agreements with Swiss banks starting with UBS. Last year, the agency finalized the last of the non-prosecution agreements under the Swiss Bank Program that involved […]