Tag Archive for Offshore Accounts

Apple’s Lobbying Saved Them $47 Billion In IRS Taxes

Ronald Marini, Tax Advisor, Miami, Florida, USA, TaxConnections
On January 18, 2018 we posted Apple to pay $38 Billion in Repatriation Taxes where we discussed that Apple would make a one-time tax payment of $38 billion to repatriate overseas cash holdings and also ramp up its spending in the U.S., as it seeks to emphasize its contributions to the U.S. economy after years of taking criticism for outsourcing manufacturing to China.
Now the ICIJ analyzes this decision by Apple to bring back hundreds of billions of dollars in offshore cash claiming a “responsibility to give back” to the United States.
Prior to the TCJA of 20107 change, many big corporations were achieving astonishingly low worldwide tax rates and amassing mountains of cash offshore. Some estimates suggest as much as $2.8 trillion has been locked in this offshore limbo. And no multinational has been better at the avoidance game than Apple.

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IRS Amnesty; The Offshore Voluntary Disclosure Program Explained In Less Than 5 Minutes

Richard Lehman, Tax Connections

American citizens and residents often have placed funds in “foreign bank accounts” in banks all over the world. There is a requirement that all of these foreign bank accounts be reported to the United States on an annual basis and that United States income taxes be paid on all of these bank deposit funds.

Many American taxpayers who have been unaware of this requirement are now being pursued for taxes and penalties for not reporting their foreign bank deposits. There are two Internal Revenue procedures that will permit American taxpayers, who have not properly reported their foreign bank deposits, and the income therefrom, to come forward and report their foreign bank deposits. This avoids significant fines and penalties on a United State taxpayer who has not reported foreign bank deposits. Read more

DOJ Seeks Tenfold Increase in Criminal Sentencing for Offshore Tax Matters

The US Department of Justice (DoJ) has announced a significant change in its criminal sentencing policy regarding offshore tax violations. The DOJ had previously Warn Potential Tax Cheats: Tax Crimes Result In Criminal Prosecution, Lengthy Prison Sentences, And Fines on April 6, 2017.

Mark Daly, DOJ Tax Division Senior Litigation Counsel announced a major new shift in how the Department of Justice plans to argue offshore tax prosecution defendants should be sentenced.

He gave a warning that the department now considers that Part 2S1.3 of the United States Sentencing Guidelines, referring to money laundering and monetary transaction reporting offences, applies to offshore tax cases, and not Part 2T (offences involving taxation), as was previously used.

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Financial Advisors Are Turning Over Your Names To The IRS

Ron Marini

The Government has added another Financial Advisor since October of 2016, Michael A. Behr, (effective 1/25/17) to their list of Offshore Banks and Foreign Financial Advisors which are turning over the names of their US 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 Committed To Stopping Offshore Tax Cheating

Ron Marini

The Internal Revenue Service today said avoiding taxes by hiding money or assets in unreported offshore accounts remains on its 2017 list of tax scams known as the “Dirty Dozen.”

Since the first Offshore Voluntary Disclosure Program (OVDP) opened in 2009, there have been more than 55,800 disclosures and the IRS has collected more than $9.9 billion from this initiative alone.In addition, another 48,000 taxpayers have made use of separate streamlined procedures to correct prior non-willful omissions and meet their federal tax obligations, paying approximately $450 million in taxes, interest and penalties.

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A Former Credit Suisse Client Gets a 7 Month Jail Sentence!

Ron Marini

We previously posted on November 7, 2016 we posted “Swiss Bank Rats Out NYU Business Professor – Results in Fine of $100M & Up To 5 Yrs in Prison” where we discussed that a former client of Credit Suisse Group AG who pleaded guilty to hiding $200 million from U.S. tax authorities was sentenced to seven months in prison after a judge granted him leniency for cooperating with prosecutors, a Justice Department official said.

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Panama Papers – Global Effects Thus Far & Continuing Impact

Ron Marini

In April 2016, we posted “Huge Leak From the Panamanian Law Firm Mossack Fonseca!” where we discuss that the offshore planning world was set on fire with the news that 11 million documents were leaked from the Panamanian law firm Mossack Fonseca.

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Offshore Compliance Programs Generate $8 Billion

IRS Urges People to Take Advantage of Voluntary Disclosure Programs… You Think?

The IRS released IR-2015-116 on Oct. 16, 2015, to remind U.S. taxpayers with undisclosed offshore accounts, that with more than 54,000 taxpayers coming in to participate in offshore disclosure programs since 2009, they should strongly consider existing paths established to come into full compliance with their federal tax obligations.

Both the Offshore Voluntary Disclosure Program (OVDP) and the streamlined procedures enable taxpayers to correct prior omissions and meet their federal tax obligations while mitigating the potential penalties of continued non-compliance. There are also separate procedures for those who have paid their income taxes but omitted Read more

2 More Swiss Banks, 57 Total, Are Turning Over Your Names To The IRS – What Are You Waiting For?

We previously posted OVDP Penalty Increased To 50% For 55 Foreign Banks Asset Management Firms! well now make 57 (54 Banks +1 Asset Management Firm) including “The 1st Swiss Asset Management Firm To Turn Over Names of US Clients Over to the IRS!

The IRS announced on October 16, 2015 that BBVA Suiza S.A. and on October 23, 2015 that et Galland & Cie SA Reaches Resolution under Swiss Bank Program.

“The multiplier effect that these agreements have on tax compliance non-willful, cannot be underestimated,” said Chief Richard Weber of IRS-Criminal Investigation (CI).

“The magnitude of the data provided by each of these agreements leads us to: more & Read more

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

Bank Leumi Enters Into Non-Prosecution Agreement With DOJ; Agrees To Release More Than 1,000 U.S. Account Holder Names

In order to avoid a fate similar to UBS, Bank Leumi recently admitted to engaging in some tax “hanky panky.” One of the largest banks in Israel, Leumi admitted that it helped U.S. taxpayers evade their taxes. How so? By helping these individuals to hide their income and assets in offshore accounts in Israel and in other parts of the world.

This did not come without a price – a steep one. To account for its criminal conduct, Bank Leumi Group will pay the IRS a whopping $270 million in fines and an additional $ 130 million to New York’s Department of Financial Services. The terms of the deal are strikingly similar to the one that UBS entered into a while ago with the United States – an admission of wrongdoing in exchange for immunity from prosecution. This is what is referred to colloquially as a “deferred prosecution agreement.” Read more

Taiwan Provided the US Financial Information on 4,273 US Green Card Holders Under FATCA!

According to The China Post The Financial Supervisory Commission’s (FSC) chairman Tseng Ming-chung met with the U.S. treasury from Nov. 2 till Nov. 5 and signed an Intergovernmental Agreement (IGA) under the Foreign Account Tax Compliance Act (FATCA) that will see Taiwanese financial institutions directly providing 4,273 Taiwanese green-card holders and American citizens’ bank account information to the U.S., Tseng said in the Legislative Yuan on November 18, 2014.

According to Tseng, the agreement is not a full tax treaty, but rather a model under the treaty to exchange tax information.

Tseng said he was given the final copy of the IGA in person on Nov. 3. The U.S.’ request Read more

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