The IRS has tightened its enforcement of the Foreign Account Tax Compliance Act (“FATCA”). FATCA was enacted in 2010 by Congress to target non-compliance by U.S. taxpayers using foreign accounts. FATCA requires foreign financial institutions (FFIs), i.e., foreign banks, to
Raju Mukhi of St. Louis MO was indicted last year for his alleged failure to file a report to the IRS on his foreign financial accounts and for filing false tax returns. United States citizens are required to report income
Federal prosecutors charged six men Tuesday with running a complicated offshore scheme that allegedly enabled clients to manipulate stocks, avoid U.S. taxes and launder hundreds of millions of dollars. An indictment unsealed in federal court in Brooklyn alleged the men
We have previously posted on the U.S. Justice Department’s program offered to Swiss banks and targeted to identifying U.S. taxpayers that have not disclosed foreign accounts to the IRS. It has now been stated that that one-third of all Swiss
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
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
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
IRS Special Agents are employed by the Criminal Investigation Division (CID) which is the law enforcement arm of the Internal Revenue Service (IRS). Special Agents conduct tax investigations that are intended to result in criminal prosecutions. They conduct criminal investigations
The Department of Justice continues to prosecute cases involving United States taxpayers who have failed to report their interests in offshore accounts. Most of the cases are for large offshore accounts, but they provide good guidance for what the US government
A doctor has been convicted of failing to disclose to US federal authorities that he maintained offshore HSBC bank accounts in India and France and hid approximately $8 million in secret foreign bank accounts. Dr. Arvind Ahuja of Wisconsin was
The Internal Revenue Service (IRS) has announced that its offshore voluntary disclosure programs (OVDPs) have collected more than $5 billion, and that it has tightened the eligibility requirements of the third program it opened in January this year. “We continue
The Internal Revenue Service announced on June 26, 2012 (IR-2012-64) that it is tightening eligibility requirements for the open-ended offshore voluntary disclosure program (2012 OVDP) that it announced in January 2012 for taxpayers with unreported income or assets, generally in
The Internal Revenue Service appears to have finally created a process to finally separate small non-resident (foreign resident) US taxpayers from larger non-resident US taxpayers at the front end, and not force everyone through the OVDI/OVDP programs. Yesterday, the IRS
In a Tax Notes Today report of statements made at the Eastern Pennsylvania Working Together Conference in Malvern, PA, Jason Kuratnick, IRS Associate Area Counsel (Philadelphia), Small Business / Self-Employed Division is reported to have said: The IRS may send
Under IRS Form 1040, at the bottom of Schedule B, Part III, on Page 2, Question 7(a) states: “at any time during the previous year, did you have any interest in or signatory or other authority over a financial account
Suppose you have a foreign bank account holding more than $10,000. You may have inherited it, used it to hide money during a dispute with your spouse or business partner, or just done it on a whim. As you try
The Foreign Account Tax Compliance Act (FATCA) is about disclosure and transparency, but in part is to catch Americans trying to stash money overseas. Controversially, FATCA orders every foreign bank to track down its U.S. account holders, and then share
American Citizens Abroad (ACA) has written to IRS Commissioner Doug Shulman of the IRS to express the organization’s profound concern that he has not answered the Directive issued by National Taxpayer Advocate Nina Olson. In her report to Congress issued
As anticipated, IRS Form 8938 Statement of Foreign Financial Assets is causing significant confusion among taxpayers attempting to complete these Forms for filing. Form 8938, Statement of Specified Foreign Financial Assets, is a new reporting form, which will be used to
The announcement by the IRS of the opening of the new Offshore Voluntary Disclosure Program (OVDP) on January 9, 2012 came as a surprise to most tax practitioners, especially since the 2011 OVDI just ended on September 9, 2011. However,
A federal grand jury in San Jose, California, last week indicted Ashvin Desai of San Jose on three counts of tax evasion, two counts of willfully aiding the preparation of materially false tax returns and three counts of failing to
Under the 2011 OVDI voluntary disclosure program, the penalties for failing to timely file Foreign Bank Account Reports, (FBAR’s) and the penalties for failure to file information returns (such as Controlled Foreign Corporation tax returns) were combined into a single
Although the OVDI program has expired, a U.S. taxpayer can still make a voluntary disclosure of foreign accounts pursuant to the IRS’s general voluntary disclosure policy. For over 50 years, the IRS has maintained a voluntary disclosure policy, under which
IRS Commissioner Shulman has invited persons with unreported foreign accounts to come forward and avail themselves of the IRS’s Voluntary Disclosure Practice. That practice is described in the Internal Revenue Manual 9.5.11.9. The Practice has a bearing upon whether the
Our office is a proud member of the New York State Bar Association (NYSBA) after reading their tax section’s detailed comments on the OVDI program. This is not an anti-tax group or self-interested association with radical comments on the OVDI
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.
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,
The IRS has petitioned for a federal court authorization to enable it to obtain information on HSBC Bank’s American account holders using their foreign accounts to evade taxes. Most of these account holders are believed to be Americans of Indian
Foreign bank account reports (FBARs) for 2010 are due on June 30, 2011 (and no extension is available). Recent guidance provides insight into who is required to file an FBAR and what is considered to be a “foreign financial account”
Last week the U.S. Justice Department asked a federal district court in San Francisco to force HSBC USA to disclose the names of their U.S. customers suspected of having secret bank accounts in India. The legal action comes after the