New Jersey Estate Planning, Probate, Tax & Elder Law Center

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Analysis of the new 2012 Offshore Voluntary Disclosure Program (OVDP)

Yesterday the Internal Revenue Service opened its Offshore Voluntary Disclosure Program (OVDP) to encourage more taxpayers with assets in undeclared foreign bank accounts to come forward.  While the OVDP was not expected by most tax lawyers and professionals, it may be welcomed by many of our clients who missed the recently closed 2011 OVDI program. [...]

Employee or Contractor?: The IRS’s New Voluntary Classification Settlement Program (VCSP)

When the IRS says “voluntary” it can sound scary. The IRS is unlikely to use this word unless the potential liability is serious. The IRS would much rather have you come forward. If you do, you’re likely to get a much better deal than if you wait for them to find you. Recent examples include [...]

Audit Beware: IRS’ Global High Wealth Industry Group

A recent article in the Wall Street Journal discussed the new IRS’ Global High Wealth Industry Group. Over 1 year ago we warned readers of the new group when Commissioner Shulman announced its formation in an address to the American Institute of CPA’s during October of 2009. In his remarks, Shulman noted the need for [...]

Extension of the OVDI Deadline of August 31, 2011

Our office represents dozens of OVDI applicants who will successfully file by the August 31, 2011 deadline. However, some taxpayers may be able to get an extension of the deadline. 90-Day Extension. Taxpayers may request an extension if they can demonstrate a good faith attempt to comply by August 31st. The extension is not automatic. [...]

What HSBC India Accountholders Can Expect From the IRS

Our firm recently informally met with a US Department of Justice official (name withheld because official was not authorized to officially speak) in Washington DC regarding the pending summons served on HSBC India to reveal account information (including names, addresses, etc.) of U.S. residents with HSBC accounts in India. The government official stated that HSBC [...]

HSBC and NRI Bank Accounts: Could It Spread to Other Banks?

The US Internal Revenue Service (IRS) has asked HSBC Bank to provide information on incomes of US residents who may be using accounts in India to evade income taxes. The move has raised several questions. First, why did US authorities single out HSBC? Second, would US IRS also approach banks like State Bank of India [...]

Another U.S. taxpayer with an offshore HSBC bank account pleads guilty

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 [...]

HSBC Expected to Disclose Account Holders Names

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 descent who hold HSBC bank accounts in India worth in excess of $100,000. The IRS [...]

HSBC Client Pleads Guilty to Conspiring to Hide Indian Accounts From IRS

An Indian-American businessman on Tuesday pleaded guilty to conspiring to defraud US tax authorities by hiding his bank accounts in HSBC India, a case which has led the IRS to probe NRIs holding accounts in the bank. Vaibhav Dahake, 44 of Somerset, New Jersey pleaded guilty before US District Judge Freda Wolfson to an indictment [...]