The IRS recently posted guidance in its OVDI FAQs (#51) whether taxpayers should opt out of the 2011 Voluntary Disclosure Initiative’s (the “OVDI”) civil penalty structure. Taxpayers who participate in the OVDI, but feel that their failure to file the FBAR form on an annual basis was “non-will”, may considering opting out. Who makes the determination
As OVDI Amnesty Deadline Nears, Fourth HSBC client customer indicted for tax evasion and fraud this year
Dr. Arvind Ahuja, a neurosurgeon and US citizen, from Greendale, Wis., was indicted yesterday by a federal grand jury in Milwaukee on four counts of willfully filing materially false tax returns and four counts of failing to file Reports of Foreign Bank and Financial Accounts (FBARs), the Department of Justice and Internal Revenue Service (IRS) announced
The recent IRS FAQ update clarifies the procedures for opting out of the 2011 OVDI and highlights certain situations in which the IRS recognizes opting out to be justified (or in fact the preferred approach). This generally includes taxpayers with reasonable cause for failure to file their FBARs. The IRS’ 2011 OVDI FAQ 51 for
Tomorrow night our firm will be presenting a three hour seminar to tax professionals on foreign account disclosure, FBARs, and OVDI at the Academy of Continuing Professional Education (ACPE): June 21, 2011 – 7:00 p.m. to 10:00 p.m. Navigating Foreign Waters: The Complex Requirements of Foreign Accounts Compliance Parag P. Patel, Esq. With the IRS
The IRS last week explained fully the possibility of opting-out of the OVDI and taxpayers’ taking their chances with an IRS examination, particularly where the non-disclosure of assets or income could be proved to not be “wilful”, and has also re-specified the conditions under which taxpayers making voluntary disclosures may qualify for a 5% offshore
The IRS said last week that it is making available to taxpayers a 90-day deadline extension to participate in the 2011 offshore voluntary disclosure initiative (OVDI). The extension would be available to taxpayers who have made a good faith attempt to fully comply by August 31, 2011, but are unable to submit a complete package,
The Department of Justice and local United States Attorneys’ Offices continue to zealously prosecute numerous cases involving U.S. taxpayers who have failed to report their interests in offshore accounts. The successful prosecutions underscore the government’s aggressive investigations and enhanced scrutiny. U.S. taxpayers who have failed to report their interests in offshore accounts should consider voluntary
Last week a Boston venture capitalist and director at a Boston bank was charged with failing to report his foreign bank account and income to the US Department of the Treasury. It is noteworthy that relatively small amounts of income, tax, and offshore assets were involved. The offshore accounts ranged from about $65,000 to $150,000.
On April 13, 2011, another U.S. taxpayer with an offshore HSBC bank account, Josephine Bhasin (United States v. Bhasin, E.D.N.Y., No. 11-cr-00268-ADS), pled guilty to charges of knowingly filing false tax returns, false amended tax returns, and false FBARs. According to court documents, Ms. Bhasin of Huntington, NY, filed a false individual income tax return
If HSBC produces these records, which is likely, it may be too late for U.S. taxpayers with undisclosed HSBC accounts to take advantage of the IRS Voluntary Disclosure Program for offshore accounts.