State And Local Voluntary Disclosure

This article is the second of a three-part series regarding the State and Local Tax consequences of doing business in multiple states. This article will discuss Voluntary Disclosure, Part 1 discussed Nexus and Part 3 will discuss the Audit Process.

The Wayfair decision changed the landscape for nexus in the sales and use tax area. It lowered the bar to establish nexus with a state, which gives a state the right to require the collection and remittance of sales and use taxes. The Supreme Court’s decision changed the nexus focus from the existence of a physical presence to an economic presence—which generally may be based on sales into the state themselves. As a result, many taxpayers may have triggered the nexus threshold, especially if a state imposes a factor presence standard for income, franchise or gross receipts taxes.

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There are around 9 million Americans living oversees, and the IRS has its sights set on those expats who aren’t up to date with their U.S. tax filing.

All American citizens and green card holders are required to file a U.S. tax return, however because the U.S. is the only developed nation to tax its non-resident citizens, many haven’t realized that they have to file. Read More

You Are Invited To Be Part of Internet History…
Join TaxConnections as we present incredible Tax Experts on Expatriate Day at the Internet Tax Summit on Monday, September 21, 2015 beginning at 7:30AM (PDT).


Listen to stories from Expatriates around the world and learn from these Tax Experts about what to do to stay compliant with U.S. Tax Laws. Learn about FBAR, FATCA, Amnesty or Quiet “Voluntary Disclosure” of Foreign Bank Accounts, Exit Taxes and so much more. Read More

Thousands of Credit Suisse Group AG’s United States clients still don’t know whether tax authorities will learn their identities as prosecutors work to conclude a three-year probe of how the bank helped them evade taxes.

We posted on February 27, 2014, Report to Congress: Credit Suisse Help US Taxpayers Hide Billions in Offshore Accounts! where we discussed the Permanent Subcommittee on Investigations (PSI) of the United States Senate held a hearing, “Offshore Tax Evasion: The Effort to Collect Unpaid Taxes on Billions in Hidden Offshore Accounts,” on Wednesday, February 26, 2014.

The PSI hearing’s stated purpose of continuing the PSI’s examination of tax haven bank Read More

Picture this: You are sitting behind your desk when your phone rings. No, it’s not your spouse calling to find out why you are late for dinner. Although if that was the first thing that came to mind, there might be some hidden meaning in it. Instead, it is a new client. His name is John. John is a resident of New Jersey. John contacts you for advice regarding foreign, unreported bank accounts in the Netherlands. You recommend that John apply to the Offshore Voluntary Disclosure Program.

As part of this process, you file amended federal income tax returns on John’s behalf. John then pays a whopping 27.5% offshore penalty on the highest aggregate balance in his foreign bank accounts during an eight-year look-back period. Finally, John pays additional taxes and penalties for each of the preceding eight years. Read More

The United States Justice Department has received 106 requests from Swiss entities to participate in a settlement program aimed at ending a long-running probe of tax-dodging by Americans using Swiss bank accounts according to a senior US official.

We first posted “Swiss Banks Agree to Plan to End Past US Tax Evasion Issues!” on August 29, 2013, where we discussed that Swiss banks were ready to pay hefty fines for sheltering United States tax fugitives under the terms of a new deal given the green light by the Swiss government.

Kathryn Keneally, a senior official of the United States DOJ’s tax division, said the department was ‘gratified’ by the response to the offer, although it does not expect that all Read More

Moshe Asher: The Tax Authority plans to provide information to relevant countries about foreign residents’ capital in Israel.

“We won’t be a tax haven for foreign residents,” said Israel Tax Authority director general Moshe Asher at the conference of the CPA Association of Jerusalem conference on December 17, 2013.

He said that the Tax Authority planned to provide information to relevant countries about foreign residents’ capital in Israel, and that these countries will reciprocate about the foreign assets of Israelis. Read More