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Tag Archive for Amnesty

The Choice: Amnesty Or Quiet Disclosure For Foreign Bank Accounts: Criminal Tax Evasion, Negligence, Or Ignorance?

Preliminary Introduction For TaxConnections Global Internet Tax Summit, September 21-25, 2015

The most recent IRS push to close “the Gap” between collected U.S. tax revenue and the total tax revenue which should be reported by U.S. citizens and alien residents of the United States has focused on offshore income concealed in foreign or offshore accounts.

U.S. citizens are liable for U.S. taxation on all income realized globally, regardless of the foreign jurisdiction in which their funds are deposited in foreign accounts.  U.S. citizens are not only liable for U.S. tax on such foreign sources of income, they are required to report all funds in excess of $10,000.00 on deposit in foreign accounts over which they have “signature authority” even if they only have a nominal “financial interest” in the Read more

More U.S. Taxpayers Admit to Secret Swiss Accounts

Why Swiss Bank Clients Who Can’t Stand the Heat Are Getting Out of the Kitchen –

Every July, people from around the world descend upon a small village in Spain called Pamplona for the fiesta of San Fermin. Encierro, or “The Running of the Bulls,” is the event at the heart of the fiesta. The fiesta is celebrated in honor of San Fermin, patron saint of Navarra, although the religious aspect would seem to have taken on a secondary role over the last number of years.

The bull-run is a spectacle unlike no other. It is defined by the level of risk and the physical ability of the runners. After the launching of two rockets, a herd of six bulls is released from Read more

Australia’s Mooted Offshore “Amnesty” – Immunity From Prosecution Unclear

Although various tax advisers and some industry bodies have already expressed enthusiasm about the apparent generous nature of the just mooted “amnesty” for Australian tax evaders with offshore interests, there is as yet no certainty of immunity from criminal prosecution being available.

In this connection, The Australian Taxation Office (ATO) does not actually have the authority to grant immunity. Only the Commonwealth Director of Public Prosecutions (DPP) has the power to grant immunity from prosecution. Under the Australian Government’s Prosecution Policy, the DPP can give favourable consideration to refraining from prosecution under a “public interest” clause. Read more

Offshore Asset And Income Amnesty Mooted By Australia’s Tax Commissioner

Nassim Kadem reports in today’s Australian Financial Review that recently appointed Commissioner Chris Jordan has mooted a new amnesty for disclosure of hidden offshore assets and income. A Tax Office official has confirmed the proposal and apparently, Treasurer Joe Hockey has indicated support for the idea.

The amnesty would cap the retrospective tax and penalty period to four years, making it relatively attractive for Australian taxpayers wanting to come clean and avoid later criminal prosecution and unlimited back taxes. It would be particularly attractive to second and third generation members of wealthy families who have “inherited” the problem of secret offshore caches. Read more

States Offer Amnesty in Attempt to Collect Tax

TaxConnections Blogger John Dundon posts about accumulated adjustment accountsEach year, many states announce amnesty programs in an effort to incentivize taxpayers to pay state tax. Most programs, in one form or another, offer partial or full interest and penalty abatement if taxpayers pay back taxes owed. While the programs seem like a win for states in theory, as a state and local tax attorney, I can promise that such programs lead to problems. Auditors in the various states are told to close down improperly completed audits in an effort to get taxpayers in the amnesty program. This, in turn, leads to poorly conducted audits that must be protested and litigated. In short, state and local tax professionals in those states should be licking their chops for the bombardment of work that will likely ensue.

The most recent states to implement a version of an amnesty program are Arkansas, Connecticut, and Louisiana.

Arkansas’ amnesty program applies to franchise taxes and runs from September 1st through December 31st, 2013. In order to participate, taxpayers must submit all reports and forms and pay the computed tax to the state. If a taxpayer meets the requirement of the deal, then Arkansas will waive all interest and penalties for delinquent taxpayers.

Similarly, in Louisiana, a Tax Amnesty program went into effect on September 23rd, 2013. The Louisiana amnesty program is broader than Louisiana in that it covers most state and local taxes. Taxpayers only have until Read more

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