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Tag Archive for OVDP

Paying Too Much CGT? Pravin Gordhan’s Tax Rate Reprieve

Hugo van Zyl

During February 2016 the beleaguered South African Minister of Finance, Minister Pravin Gordhan, made a serious attempt to balance government’s books.

Gordhan was called back after Minister Nene was removed from his position, by President Zuma early December 2015. The true reason for this politically motivated musical chairs, appointing three ministers in less than 4 days, remains a mystery. Point is Nene was removed and Gordhan had to step in and rescue the cash flow and ensure the country did not face junk status.

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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

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

BloggerRonald-3-7-2016

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

93 Swiss Banks Are Turning Over Your Names To The IRS – What Are Your Waiting For?

Ronald Marini

The IRS keeps updating its list of foreign banks 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.  On January 25, 2016 the Justice Department Announced that Leodan Privatbank AG (Leodan) is the 93rd Swiss Bank to reached a resolution under the department’s Swiss Bank Program.

Under the program, banks are required to:

Make a complete disclosure of their cross-border activities; Read more

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

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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

Finally The Senate Foreign Relations Committee Approves 8 Tax Treaties!

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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

Unprecedented Success for US Offshore Amnesty Programs!

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According to the Internal Revenue Service:

Since OVDP Began in 2009, There Have Been > 54,000 Disclosures!
The IRS has collected > $8 Billion.

We previously discussed this in our post “Offshore Compliance Programs Generate $8 Billion” However, the figures have risen sharply since the IRS’ last progress report in January this year, when it announced that the OVDP schemes had attracted 54,000 disclosures and USD7 billion in tax.

It is believed that most of the additional 30,000 taxpayers who have volunteered since then, have been attracted by the ‘streamlined’ program launched in June 2014 for ‘non-wilful’ taxpayers. This program originated from the IRS’ Read more

Offshore Compliance Programs Generate $8 Billion

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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?

Ronald Marini picture24

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

Republican and Democratic Lawmakers Vow to Push Tax Treaties Delayed by Sen. Paul!

Ronald Marini picture23

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. Read more

OVDP And Double Counting: Oh The Agony! – Part II

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This is a continuation of Part I. This hypothetical pertains to a taxpayer who has applied to OVDP and who has transferred assets from one foreign account, which was recently closed, to another during the disclosure period.

This is a simple example, yet it illustrates some of the common mistakes that are associated with double counting.

Joe has applied to the OVDP. He had two foreign accounts in 2010: one at Bank A and another at Bank B.

The opening balances in each account were as follows: Read more

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