Tax, Estate Planning, Probate & Elder Law Center

Your Information source for tax, wills, trusts, offshore asset planning, estate tax minimization, powers of attorney, living wills, health care directives, special needs trusts, asset protection, charitable giving, guardianship, succession planning, retirement and estate administration.

Finally. Government Accountability Office makes recommendations to the IRS for tax laws education to immigrants

In latest report from a government watchdog agency called the Government Accountability Office (GAO) the GAO makes recommendations to the IRS, and the IRS pays attention. Those recommendations could put some taxpayers in trouble, but some are beneficial. Particularly helpful tax laws education commentary regarding offshore assets. Below is an excerpt from the report.   In our [GAO] case [...]

IRS’s four offshore programs have netted 39,000 taxpayers and over $5.5 billion

The Internal Revenue Service has collected over $5.5 billion in revenue from taxpayers who came forward and reported on their foreign holdings under its Offshore Voluntary Disclosure Programs, but it could be missing billions more in revenue from tax evaders, according to a new report. The report, issued by the Government Accountability Office, found that as [...]

Government Report Advises IRS to Increase Awareness of Offshore Account Rules to Help Immigrants

The Internal Revenue Service’s four amnesty programs for those who have undeclared offshore accounts have resulted in more than 39,000 disclosures by taxpayers and more than $5.5 billion in revenues as of December 2012. A report Friday by the Government Accountability Office (GAO) also reveals that the IRS could draw more voluntary disclosures from these [...]

Quiet or Silent Disclosure Commentary from the Government Accountability Office

The recent report from a government watchdog agency called the Government Accountability Office (GAO) shows how well the IRS attack on offshore tax evasion is coming. The GAO makes recommendations to the IRS, and the IRS pays attention. Those recommendations could put some taxpayers in trouble. Particularly concerning is the Quiet Disclosure commentary. Below is an excerpt from the [...]

HSBC customer Josephine Bhasin Criminal Sentencing Very Light

HSBC customer Josephine Bhasin was sentenced last month. Josephine Bhasin of New York earlier pleaded guilty before U.S. Magistrate Judge E. Thomas Boyle in Central Islip, N.Y., to filing a false 2008 individual income tax return that did not report her ownership of a bank account in India at the Hongkong and Shanghai Banking Corporation [...]

Foreign HSBC Bank Customer Avoids Jail: Given Three Years’ Probation

A Wisconsin neurosurgeon convicted of tax charges related to a HSBC bank accounts owned abroad that held $8.76 million was spared prison and ordered to serve three years’ probation, according to the Internal Revenue Service. Arvind Ahuja was sentenced yesterday in federal court in Milwaukee, where he was convicted Aug. 23 of filing a false [...]

Opting Out of the Offshore Voluntary Compliance Initiative Programs

As with other IRS’ 2009 and 2011 offshore voluntary compliance initiatives, the 2012 program gives no discretion to the IRS agents to reduce penalties. If a participant does not believe that he or she should have to pay the 27½% penalty, their only choice is to “opt out” of the program, in which case the [...]

National Taxpayer Advocate Criticizes IRS over handling of offshore voluntary disclosures

The 2012 National Taxpayer Advocate (NTA) Annual Report to Congress criticized current IRS practices in the Offshore Voluntary Disclosure Program (OVDP) that hinder voluntary compliance by penalizing taxpayers who are entitled to a reasonable cause exception from willfulness. One of the major complaints of the 2011 OVDI was that penalty presumed willfulness. Many taxpayers and [...]

Appeals of penalties imposed during the Offshore Voluntary Opt-Out

When a taxpayer has a tax increase though a civil tax audit (or examination, in IRS terminology), a taxpayer has the right to appeal that increase administratively and through court, if unsuccessful administratively.  For taxpayers not willing to accept the 27.5% FBAR-equivalent penalty, they may opt-out of the standard FBAR penalty scheme and argue for [...]