On July 31, 2015, the President signed into law H.R. 3236, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015. Buried in the bill are some important changes to due dates for returns, including FinCen Report 114 (FBAR). Starting with the 2016 tax year, the due date […]
Category: Offshore Accounts/International Tax Disputes
The U.S. District Court for the Western District of Washington has upheld FBAR penalties of $10,000 for tax years 2005 through 2008, but admonished the IRS for what it said was “arbitrary” and “capricious” conduct. As a result, the court ordered that any additional interest or late payment penalties are […]
As the U.S. government’s much publicized crackdown on Swiss banks continues, they may be turning their focus to Southeast Asia, where a Singaporean asset-management firm has fallen under criminal investigation. The firm is suspected of accepting transfers from U.S. taxpayers who were forced to shut down their undeclared Swiss accounts […]
Rothschild Bank AG and Banca Credinvest SA are the two latest Swiss Banks to settle with U.S. authorities as part of the Department of Justice’s ongoing Swiss Bank Program. In exchange for non-prosecution agreements, the banks will pay fines and turn over detailed information about their American clients. Rothschild was […]
At an annual Offshore Alert conference, the director of the IRS offshore voluntary compliance initiative revealed that the IRS recently issued John Doe summonses to seven more foreign private banks. While he did not reveal which banks the summonses were issued to, he did say that they were not limited […]
Facing billions of dollars in potential fines at the hands of U.S. authorities, Swiss banks are scrambling to convince their American clients to voluntarily disclose their accounts to the IRS. Long known for its secrecy, Switzerland’s banking industry has been turned upside down due to an ongoing U.S. onslaught against […]
As the Department of Justice continues its efforts to prosecute individuals involved in offshore tax evasion, approximately two dozen indicted Swiss bankers remain fugitives in Switzerland. Although the United States and Switzerland have an extradition treaty, Switzerland will not extradite individuals accused of tax crimes. While these individuals are free […]
A former Swiss banking executive has pleaded guilty in a Florida court to charges of helping U.S. clients evade taxes. Hansruedi Schumacher, who cooperated with the U.S. government and testified in another prominent offshore prosecution, will face sentencing later this year. Schumacher, 56, was the Regional Market Manager for UBS’s […]
The Foreign Account Tax Compliance Act (FATCA), a U.S. law passed in 2010 that requires foreign financial institutions to exchange information with the IRS about American account holders, is set to face challenges in both the courts and in Congress. Since 2012, the Treasury Department has negotiated Intergovernmental Agreements with […]
By Brown, PC of Brown, PC posted in Offshore Accounts/International Tax Disputes on Thursday, March 26, 2015. Last summer, the IRS announced sweeping changes to its ongoing offshore compliance initiatives. The biggest change was the announcement of new Streamlined Compliance Procedures. Under these procedures, eligible taxpayers who resided in the […]