IRS Hiring Special Agents…Now That OVDP Protection Has Ended As many experienced practitioners will tell you, the end of OVDP signals a nail in the coffin for many taxpayers seeking amnesty under the traditional offshore program. Yes, the Streamlined Program and Reasonable Cause are still available, but only OVDP facilitated a means of safe compliance…
FBAR & Whistleblower (2018) – IRS Laws Put Foreign Accounts in Jeopardy As if there are not enough things in life for you to worry about, right? If you are like many of our clients, you are a motivated entrepreneur, executive, doctor, lawyer, entertainer, sports figure, or other individual with foreign income, assets, accounts and investments….
China Cracks Down on Tax Evasion with a $70 Million Evasion Penalty The U.S. is not alone in working toward eliminating tax evasion. And, nobody is immune from getting hit with a tax evasion charge or penalty — even celebrities. Most recently, the Chinese government penalized a very notable actress upwards of $70 Million. Fan…
Switzerland Reports 2 Million Accounts (Swiss FATCA & FBAR Risks) You know it is a bad day in offshore banking, when Switzerland (yes, that Switzerland) announced (via the Swiss Federal Tax Administration website) that it has already exchanged accountholder information with multiple EU countries and many others. While the transfer was to other EU countries (via AEOI)…
FBAR is Becoming an Even Bigger Mess with Global Consequences FBAR litigation is becoming an epidemic without borders. While FBAR penalties can range from a warning letter all the way to 100% penalties in a willful, multi-year audit, there is no straightforward, bright-line test to determine willful vs. non willful. What does FBAR Willful Mean?…
