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Tag Archive for OVDP

Oh Oh, We Are Half Way There … 50 Swiss Banks Are Turning Over Their US Client’s Names

The number of Swiss banks that have entered deferred prosecution agreements with the U.S. government keeps growing. 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.

On September 17, 2015 we posted “48 Swiss Banks Are Turning Over Their US Client’s Names”, well make that 50 now. The IRS recently added St. Galler Kantonalbank AG (SGKB) and E. Gutzwiller & Cie, Banquiers on 9/17/15. The complete list is as follows, as of 9/17/15: Read more

OVDP Penalty Increased To 50% For 48 Foreign Banks!

The new revisions to the US offshore voluntary disclosure initiative, 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 and 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, as of 9/16/15: 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

OVDP Penalties Increased To 50% For 32 Foreign Banks!

The new revisions to the US offshore voluntary disclosure initiative, 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 and 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

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 25 Foreign Banks

The new revisions to the US offshore voluntary disclosure initiative, 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 and 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

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

OVDP Penalty Increased To 50% For 19 Foreign Banks

The new revisions to the US offshore voluntary disclosure initiative, 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 and 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

Pinter Bank Swells List of Foreign Banks To Which Enhanced OffShore Penalty Applies

Most U.S. taxpayers who enter the IRS Offshore Voluntary Disclosure Program must pay an offshore penalty equal to 27.5 percent of the highest year’s aggregate balance of their offshore accounts during an eight-year look-back period. On August 4, 2014, the IRS increased this penalty from 27.5% to 50% if the following conditions exist:

(1) At the time the taxpayer initiated their disclosure, one or more of the following applies:

a. A foreign financial institution at which the taxpayer had an account had been publicly identified as being under investigation, the recipient of a John Doe Summons or is cooperating with a government investigation, including the execution of a deferred prosecution agreement or non-prosecution agreement; or Read more

3rd Swiss Bank Agrees To Turn Over Names To The IRS

On May 12, 2015, we posted on TaxConnections “More & More Swiss Banks Are Striking Deals With the DoJ!” where we discussed that Vadian Bank AG (Vadian), located in St. Gallen, Switzerland, became the second Swiss Bank  to reach a resolution under the DOJ’s Swiss Bank Program.

On Friday, May 11, 2015 the The Department of Justice (DoJ ) announced Finter Bank Zurich AG (Finter), located in Zurich, Switzerland, was the 3rd Swiss Bank to reach a resolution under the department’s Swiss Bank Program.

“I would stay tuned,” Acting Assistant Attorney General Caroline Ciraolo of the Justice Department’s Tax Division, adding that a number of non-prosecution agreements will Read more

OVDP Penalty Increased To 50% For 15 Foreign Banks

The new revisions to the US offshore voluntary disclosure initiative, 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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