Archive for OVDP

144 Offshore Banks & Now Financial Advisors Are Turning Over Your Names To The IRS – What Are Your Waiting For?

Ron Marini

On May 26, 2016 we posted 97 Offshore Banks Are Turning Over Your Names To The IRS – What Are Your Waiting For? and since then, the Government has added 47 more banks and financial advisors to this list bringing the number to 144 offshore banks and foreign financial advisors. The IRS keeps updating its list of foreign banks which are turning over the names of their U.S. Account Holders, who are now subject to a 50% (rather than 27.5%) penalty in the IRS’s Offshore Voluntary Disclosure Program (OVDP). This penalty is based on the highest account balance measured over up to eight years.

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IRS CI Changes Phone & Fax Numbers for OVDP Preclearance!

Ron Marini

So here I am just another 59-year-old tax attorney who is sure that technology has it out for him, sitting in my office trying to get a few more cases moving forward while I wait for the Labor Day weekend, and I’m trying to fax (267) 941-1115 (the OVDP preclearance number) a preclearance for yet another client who wants to enter the OVDP program.

Naturally, I’m waiting for my E-Fax confirmation that this request for preclearance has gone through to the IRS and today I received not 1 but 2 messages that my E-Fax, that I rely on for communicating with the IRS, was not able to deliver either of my faxed requests.

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OVDP Is Not The Only Option For Taxpayers With Undisclosed Foreign Bank Accounts!

Ronald Marini

With the implementation of FATCA, the ongoing efforts of the IRS and the Department of Justice to ensure compliance by those with U.S. tax obligations have raised awareness of U.S. tax and information reporting obligations with respect to non-U.S. investments.

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97 Offshore Banks Are Giving Names To The IRS—What Are You Waiting For?

R M 6.1

The IRS keeps updating its list of foreign banks which are turning over the names of their U.S. account holders. These people are now subject to a 50% (rather than 27.5%) penalty in the IRS Offshore Voluntary Disclosure Program (OVDP). This penalty is based on the highest account balance measured over up to eight years.

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U.S. Department of Justice Gets Its 1st FATCA Conviction!

Ron Marini May 17 2016

DoJ announced on May 9, 2016, that Gregg R. Mulholland, a dual U.S. and Canadian citizen of San Juan Capistrano, California and Vancouver, Canada, Age: 46 and secret owner of Legacy Global Markets S.A. (Legacy), an offshore broker-dealer and investment management company based in Panama City, Panama, and Belize City, Belize, pleaded guilty to money laundering conspiracy for fraudulently manipulating the stocks of more than 40 U.S. publicly-traded companies and then laundering more than $250 million in profits through at least five offshore law firms.

When sentenced, Mulholland faces up to 20 years in prison.

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Is This Canadian Baby An American Tax Cheat?

Pati (3)

Is This Canadian Baby An American Tax Cheat?

A Canadian baby is learning about taxes, banking and activism at a tender age. The eight month old girl received a “Dear Valued Customer” letter from her Canadian bank when she was six months old advising her that her account information may be provided to Canada Revenue Agency to pass on to IRS.  The wee “Valued Customer” was directed to complete, sign and mail forms to the bank.

Baby Elle (not her real name) and her Canadian parents were Read more

Commentary on the The Panama Papers & The Disclosure of 14,000 Clients’ 214,000 Offshore Companies Files and Assets


A leak of searchable 11.5 million files, that’s 2.6 terabytes of data, from the embattled offshore services provider Mossack Fonseca. Every email, client note, asset and income statement, instruction, communication, .. since 1977!  2.6 terabytes of data, 11.5 million files, is a lot of files and scanned documents to comb through, so this leak is potentially, and probably, more significant than the 2014 ICIJ reported on leak or even the HSBC and UBS’ leaks. Read more

Penny Wise And Pound Foolish


Philip Wrigley had a problem. As the notoriously parsimonious owner of the Chicago Cubs in the 1970s, Mr. Wrigley did not want to spend big money to attract top players. But as the savvy owner of a successful confectionary business he also knew that no one would buy tickets to see a perennially second-division ball club. So he came up with the idea of the “loveable losers” a slightly-above average team that could win 80 or 85 games in a season.

The point of this story is that Mr. Wrigley did not want to be penny Read more

Hiding Money Offshore Resides on the Dirty Dozen List of Tax Scams for the 2016 Filing Season


On Thursday, February 11, 2016 we posted IRS “Dirty Dozen” Tax Scams for 2015 we discussed that the Internal Revenue Service wrapped up the 2015 “Dirty Dozen” list of tax scams today with a warning to taxpayers about aggressive telephone scams continuing coast-to-coast during the early weeks of this year’s filing season, where it stated that avoiding taxes by hiding money or assets in Read more

FATCA 2015 Roundup: It’s All Serious Business!

TaxConnections Member Manasa Nadig

A lot has been written about the Foreign Account Tax Compliance Act {FATCA} in the past year. As this year comes to a close and I write up this post, I wanted to give you all, my dear readers a synopsis at your finger-tips, a round-up, if you will of some major FATCA events for 2015:

1. FBAR Deadlines Changed:

On July 31, 2015 President Obama signed the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 into law, which modified the due date of several key forms for Americans with foreign income and Americans living abroad. That includes the Report of Foreign Bank and Financial Accounts, or Form 114, colloquially known as the FBAR.

Any U.S. person with a financial interest in, or signatory authority over, foreign financial accounts must file the FBAR, if at any time, the aggregate value of their relevant foreign account or accounts exceeds $10,000. An account over Read more

Its Official – The the 5th Amendment DOES NOT Trump the Required Records Doctrine!

Ronald Marini picture40

On Tuesday, October 27, 2015, we posted US Supreme Court Asked to Consider Whether the 5th Amendment Trumps the Required Records Doctrine? were we discussed the Third Circuit ruling that a married couple must turn over their foreign bank account records to the Internal Revenue Service, saying the couple can’t shield themselves by asserting their Fifth Amendment right against self-incrimination.

This comes after our post “Fifth Amendment Does Not Apply to Offshore Banking Records,” where we discuss that under the Required Records Doctrine, and a taxpayer who is the subject of a grand jury investigation into his use of offshore bank accounts cannot invoke the privilege to resist compliance with a subpoena seeking records kept pursuant to the Bank Secrecy Act, the U.S. Court of Read more

Your Field Guide To Foreign Account Disclosure Programs – Which Is Your Pick?

Manasa Nadig - 11-25-15

There is a lot of buzz going around these days about FBARs, foreign accounts, foreign corporations, IGAs, tax treaties, more & more Swiss banks on the roll-call list, you name it and they cry “FATCA”! Confusion all-around, fear mongers are having a field day, may be rightfully so, fines are high and penalties higher. People are ready to hit the panic button. Or so one would think!

To quote my favorite Buddhist teacher, Thich Nhat Hanh here, “People have a hard time letting go of their suffering. Out of a fear of the unknown, they prefer suffering that is familiar.”

If you are wondering what a Thich Nhat Hanh quote is doing on a tax blog but you have one hand hovering over the panic button, just think about it…without going into many of Buddhism’s wonderful practices let me assure you, do decide to end your suffering, however first- DON’T PANIC! Second, hire yourself a good Enrolled Agent who Read more