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 […]
We regularly represent taxpayers, businesses and tax preparers in Texas and beyond facing potential tax-related criminal investigation or charges by the IRS Criminal Investigation division. This week, the IRS announced in a news release that it had released its fiscal year 2016 annual report of Criminal Investigation activities. Criminal defense […]
On the campaign trail, Donald Trump said he would get rid of the federal estate tax if elected president. So far, it’s still around. To be sure, the estate tax only affects a small percentage of estates. But it’s part of a larger tax-planning picture that also includes two other […]
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 […]
For many decades, Switzerland has held the gold standard in banking secrecy. No one would know if you had accounts there and many investors with financial interests in the United States – U.S. citizens or otherwise – used this loophole to avoid taxation of large sums. The long-held tradition of […]
A bill aimed at obtaining greater information from foreign banks about US citizens and corporations with overseas accounts was introduced recently in Congress. If passed, the new law would curb the use of offshore accounts by US citizens to shield assets from taxation and severely penalize those individuals and organizations […]
With $70 billion per year in uncollected taxes at stake, the Internal Revenue Service (IRS) is cracking down on offshore tax evasion. The concentrated effort began in earnest last year after an extensive investigation into the activities of the Swiss banking giant UBS AG uncovered the largest offshore tax evasion […]