hsbc – Tax, Estate Planning & Probate Law Center

Trinidad and Tobago and the United States sign new agreement to exchange of information under FATCA

31 Aug 16

Last week Trinidad and Tobago and the United States signed an agreement to facilitate automatic exchange of information under the US Foreign Account Tax Compliance Act (FATCA). FATCA, enacted by the US Congress in 2010, is intended to ensure that

India and the US have agreed to collaborate on offshore tax evasion

21 Apr 16

India and the US have agreed to again enhance collaboration on tackling offshore tax evasion and increase cooperation in sharing of cross-border tax information after the United States Treasury and India’s Ministry of Finance met last week. Following the conclusion

New Leak of Offshore Accountholders Highlights the Need to Clean Up

05 Apr 16

The U.S. Justice Department is reviewing reports about the offshore financial arrangements of global politicians and public figures based on 11.5 million leaked files from Panamanian law firm Mossack Fonseca, a department spokesman said yesterday. The department is determining whether

ABA COMMENTS ON THE 2014 OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND THE STREAMLINED PROGRAMS

30 Oct 15

We are members of the American Bar Association Section of Taxation, which recently submitted comments to the IRS on the IRS Offshore Voluntary Disclosure Program (“OVDP”), the Streamlined Domestic Offshore Program (“SDOP”), and the Streamlined Foreign Offshore Program (“SFOP”). The comments are

India and US signed FATCA Agreement Today

09 Jul 15

India and the US today signed an agreement to implement the Foreign Account Tax Compliance Act (FATCA) that will facilitate exchange of information between the two countries starting on October 1, 2015. FATCA was signed by Revenue Secretary Shaktikanta Das

India Expected to Sign FATCA Agreement Tomorrow

08 Jul 15

India is expected to sign an inter-governmental agreement (IGA) for the US tax compliance law Foreign Account Tax Compliance Act (FATCA) tomorrow. FATCA is aimed at combating possible tax evasion by Americans through financial entities of other countries. FATCA is a

The Tax Issues of Expatriation

26 May 15

The “United States Permanent Resident Card”, also known as a Green Card, as a work and residence permit for the USA of unlimited duration and as an immigration visa, constitutes an admission ticket to the USA. However, possession of a

IRS expands use of Subpeonas

18 May 15

The U.S. Internal Revenue Service is planning to broaden the use of subpoenas of documents in cases where the name of a taxpayer under investigation is not known. The so-called John Doe summonses were a breakthrough for the IRS in

Beware: India to sign FATCA agreement with US for sharing of information

09 Apr 15

Earlier this week, the Indian Cabinet, chaired by Prime Minister Narendra Modi, approved signing of an Inter-Governmental Agreement (IGA) between India and the U.S. for implementation of the U.S. Foreign Account Tax Compliance Act (FATCA). Indian Finance Minister Arun Jaitley this

Seminar: Navigating Foreign Waters: The Complex Requirements of Foreign Accounts Compliance on US tax laws

02 Mar 15

With the IRS aggressively targeting taxpayers with unreported offshore accounts, tax professionals must know benefits and pitfalls of offshore accounts. Our firm presented technical seminars titled Navigating Foreign Waters: The Complex Requirements of Foreign Accounts Compliance on US tax laws to tax professionals on foreign account disclosure,

Hiding Money or Income Offshore Among the “Dirty Dozen” List of Tax Scams for the 2015 Filing Season

31 Jan 15

IR-2015-09, Jan. 28, 2015 WASHINGTON — The Internal Revenue Service today said avoiding taxes by hiding money or assets in unreported offshore accounts remains on its annual list of tax scams known as the “Dirty Dozen” for the 2015 filing

New Report: Delinquent Taxpayers Could be Identified at US Border Crossings

19 Oct 14

The Internal Revenue Service’s collection efforts need to be improved to make sure that delinquent taxpayers residing in foreign countries comply with their U.S. tax obligations, according to a new government report. The report, from the Treasury Inspector General for Tax

What Is The Difference Between the SDOP and the Current OVDP program?: Willfulness

03 Oct 14

What Is The Difference Between the SDOP and the Current OVDP program? The Streamlined Offshore Procedures (SDOP and SFOP) liberalizes the old restrictions and rewards taxpayers that disclose their offshore assets with a lower penalty and a very low tax.

New IRS internal procedure guidance for Streamline Filing Compliance Procedures

03 Sep 14

The IRS has published new IRS internal procedure guidance with IRM changes dated 8/13/14. The guidance is numbered WI-21-0814-1244 and titled “Streamline Filing Compliance Procedures for Accounts Management International IMF”. The guidance is here. The general legal rule is that IRM

50% Penalty for Taxpayers Who Hold Accounts at a Bank Under Investigation

21 Jun 14

The Internal Revenue Service announced last week changes to its programs for taxpayers with undeclared offshore accounts, the latest step in a five-year campaign against such accounts held by U.S. taxpayers. The modifications greatly eased penalties for people who were unaware

Swiss Bank Disclosure Round Up

02 Jan 14

A host of Swiss banks have signaled their readiness to work with U.S. officials in a crackdown on wealthy Americans evading taxes. Many more are expected to follow in the coming weeks, as Switzerland’s cherished bank secrecy slowly gets wound back.

More Swiss Banks Agree to Cooperate with the IRS

31 Dec 13

Lombard Odier & Cie and VP Bank (Switzerland) last week became the latest Swiss banks to say they would work with U.S. officials in a crackdown on lenders suspected of helping wealthy Americans evade taxes through hidden offshore accounts. Unlisted

Argue for No Penalty and a Warning Letter for FBAR Violations

22 Dec 13

The IRS may send a warning letter in lieu of asserting penalties for failure to file a Form TD F 90-22.1, “Report of Foreign Bank and Financial Accounts,” if it would be sufficient to bring the individual into compliance, an

Swiss Banks are Pressuring Customers to Disclose

21 Dec 13

Swiss banks are pressuring current and former U.S. account holders to disclose undeclared assets to the Internal Revenue Service. In some cases, the banks are freezing accounts unless clients can prove they have declared the account to the IRS—or that

US Department of Justice Encourages Swiss banks to Disclose Information

15 Dec 13

Last week the Tax Division of the Department of Justice strongly encouraged Swiss banks that want to seek non-prosecution agreements to resolve past cross-border criminal tax violations to submit letters of intent by the Dec. 31, 2013 deadline required by

More Swiss Banks Agree to Disclose US Customers Accounts: Expect More Customer Letters to be Sent

12 Dec 13

As of yesterday, three Swiss banks have agreed to participate in a U.S. disclosure program aimed at lenders suspected of aiding tax evasion by Americans. Many more expected and thousands of letters are being sent to US customers with Swiss

New FinCEN Form 114 (FBAR) Filing Rules Announced

29 Sep 13

Responding to the needs of many filers who submit Reports of Foreign Bank and Financial Accounts (FBARs) jointly with spouses, or wish to submit them via third-party preparers, the Financial Crimes Enforcement Network (FinCEN) today introduced FinCEN Form 114(a), Record

Foreign Account Tax Compliance Act (FATCA) online registration program is launched

26 Aug 13

The Internal Revenue Service on Monday launched an online registration program for the hundreds of thousands of financial firms around the world that must comply with a U.S. anti-tax evasion law or risk being shut out of financial markets. Starting

Finally: IRS Reminds Those with Foreign Assets of U.S. Tax Obligations

29 May 13

The IRS has finally decided that educating taxpayers and tax advisors of tax obligations of foreign assets and income would be helpful and encourage compliance. The recent education announcements appear to address the IRS’ alleged shortcomings in educating taxpayers with

HSBC Customer Avoids Jail in Tax Evasion Case

23 May 13

A New Jersey businessman who cooperated with prosecutors avoided prison after admitting he conspired with five HSBC Holdings bankers to hide his Indian bank accounts from U.S. tax authorities. Vaibhav Dahake, 46, was sentenced to one year of probation yesterday

HSBC Bank Expects Significant Penalties from US Government for Violations

18 May 13

Global bank HSBC has said it may face “significant” penalties from the US authorities with regard to an ongoing probe into suspected tax evasion by the US-based clients of its Indian unit, among other cases. The US tax department is

COURT AUTHORIZES SERVICE OF JOHN DOE SUMMONS SEEKING THE IDENTITIES OF U.S. TAXPAYERS WITH OFFSHORE ACCOUNTS AT CIBC FIRSTCARIBBEAN INTERNATIONAL BANK

30 Apr 13

WASHINGTON – The Justice Department announced that late yesterday a federal court in San Francisco entered an order authorizing the Internal Revenue Service (IRS) to serve a John Doe summons seeking information about U.S. taxpayers who may hold offshore accounts

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