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Tag Archive for Offshore Voluntary Disclosure Program

Offshore Tax Suit Switch From OVDP Doesn’t Block Collection

Ron Marini

Three taxpayers seeking to switch over to the IRS’ new “streamlined” compliance program for unreported offshore income argued to a D.C. Circuit panel Tuesday that their lawsuit is not foreclosed by the Anti-Injunction Act’s bar on pre-enforcement tax challenges, attacking the government’s key defense in the case. The case is Maze et al. v. Internal Revenue Service et al., case number 16-5265, in the U.S. Court of Appeals for the District of Columbia Circuit.

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The OVDP Program May End After 2017

Ron Marini

U.S. taxpayers who have foreign bank and/or financial accounts should be watching the clock. The window to voluntarily report foreign accounts in order to mitigate IRS penalties may be ending after 2017.

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IRS Nets $10 Billion From More Than 100,000 Taxpayers In The OVDP Programs

Ron Marini

The IRS, in news release IR 2016-137, highlighted the accomplishments of its Offshore Voluntary Disclosure Program (OVDP) and encouraged taxpayers with undisclosed offshore accounts to come into compliance with the federal tax obligations. The OVDP and streamlined compliance programs have been used to bring over 100,000 taxpayers into compliance and have brought in over $10 billion in taxes, interest, and penalties.

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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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Cheap Shelf Or Top Shelf?

Many people make purchase decisions based on cost, and little else. “Motor oil is motor oil,” they insist. In the minds of many, it is pure folly to pay X dollars per month for auto insurance when another company provides the same service for a mere Y dollars. Or, they ask rhetorically, what moron would pay X dollars per gallon for gasoline when the station a quarter-mile down the road only charges Y dollars?

But, as the corporate shills at Valvoline were quick to remind Earl, cost is only one element in a purchase decision. As many of us Read more

Story of A Good Citizen Who Reports Foreign Bank Accounts But Forgets FBARs! Huh?

I have to say today’s blog post was triggered by a phone call a few weeks ago. The would-be client wanted to report his foreign bank accounts. Apparently, this good citizen had all his I’s dotted & T’s crossed – so to speak – so what was the problem you ask? I hate to say this, but it happens more than you would think. He did not know there were additional reporting requirements involved when it came to bank accounts in foreign financial institutions. (More on FBAR thresholds in my post here)

You have to know that the IRS will not impose a penalty for the failure to file the delinquent FBARs if you “properly” reported the foreign bank accounts on your US tax returns, and paid tax on the income from these accounts and have not been contacted by the IRS for an income tax examination or a request for the delinquent returns has not been made by them. Read more

Finally The Senate Foreign Relations Committee Approves 8 Tax Treaties!

We previously posted on November 2, 2015, Republican and Democratic Lawmakers Vow to Push Tax Treaties Delayed by Sen. Paul! where we discussed that over a year ago, we posted U.S. Senator Rand Paul Continues To Block 5 Important Tax Treaties where we discussed that the U.S.-Switzerland tax treaty remains stuck in the Senate after Sen. Rand Paul (R-Ky.) blocked an effort to propel it forward by Senate Foreign Relations Committee Chairman Robert Menendez (D-N.J.) When a bipartisan Senate panel lambasted Swiss bank Credit Suisse for helping rich Americans evade billions in taxes, some watching the high-profile hearing couldn’t help but notice that Sen. Rand Paul sticks out like a elephant in the room. Senator Rand Paul on Wednesday June 4, 2014 again blocked the U.S. Senate from moving toward ratifying five pending tax treaties, saying they would make it easier for foreign governments to invade the privacy of Americans. Now Treaties with: 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

OVDP Penalty Increased To 50% For 55 Foreign Banks Asset Management Firms!

On September 17, 2015  we posted “OVDP Penalty Increased To 50% For 48 Foreign Banks!” well now make 55 (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 DoJ announced on October 8, 2015 that Schaffhauser Kantonalbank (SHKB) has reached a resolution and is turning over names of its US depositors! The IRS keeps updating its list of foreign banks where the holders of these offshore accounts are 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.

The complete list is as follows, as of 10/8/15: Read more

OVDP Penalty Increased To 50% For 27 Foreign Banks

The new revisions to the US offshore voluntary disclosure initiative, now provides for an increased 50% FBAR Penalties for ‘Willful’ Non-Disclosers.

This group includes those individuals who have offshore bank accounts with a foreign financial institution which has been publicly identified as being under investigation, or is cooperating with a government investigation. IRS has published a list of those foreign financial institutions or facilitators.

The complete list is as follows:

1. UBS AG Read more

OVDP Penalty Increased To 50% For 23 Foreign Banks

The new revisions to the US offshore voluntary disclosure program, which we posted on 6/18/14 “IRS Makes Changes to Offshore Programs; Revisions Ease Burden and Help More Taxpayers Come into Compliance“, now provides for an increased 50% FBAR Penalties for ‘Willful’ Non-Disclosers.

This group includes those individuals who have offshore bank accounts with a foreign financial institution which has been publicly identified as being under investigation, or is cooperating with a government investigation. IRS has published a list of those foreign financial institutions or facilitators.

The complete list is as follows: Read more

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