California Tax Law Blog

The United States and Barbados Come to Terms on an IGA

The United States and Barbados Come to Terms on an IGA

| Dec 18 | OVDI Program, Tax Law Blog | No Comments
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When many taxpayers in the United States think about potential tax havens to stash away their money, there are generally a few countries that come to mind: Switzerland, the Cayman Islands, or even Luxembourg. But the United States doesn’t want to leave any stone unturned in its search for U.S. residents that have undeclared accounts overseas. Last month, the U.S. and Barbados officially entered into an Intergovernmental agreement that aims to create a level of transparency between the IRS and financial institutions in the eastern Caribbean. This development echoes a familiar warning to any taxpayers that have accounts that remain undisclosed to the IRS: come forward now by filing an FBAR, or face the consequences.

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Facebook, Twitter… E-Trak? How the IRS is Using Modern Technology to Catch Taxpayers

Facebook, Twitter… E-Trak? How the IRS is Using Modern Technology to Catch Taxpayers

| Dec 11 | OVDI Program, Tax Law Blog | No Comments
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It has been over 65 years since George Orwell’s 1984 introduced the idea of “big brother”, a notion that has become increasingly realistic with the explosion of technological innovation over the past 30 years. Another trending belief is that the government is behind in the times, from an information technology standpoint. What many Americans don’t know is that the latter may be not completely accurate. As it turns out, the IRS is using the same technology that social media sites such as Facebook and Twitter use, everyday. If you’ve been selected for an IRS tax audit, you should know about the new software the government is using to catch tax evasion.

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Massachusetts Dentist Pleads Guilty to Tax Evasion

Massachusetts Dentist Pleads Guilty to Tax Evasion

| Dec 09 | Criminal Tax Representation, Tax Law Blog | No Comments
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Paying taxes is often like pulling teeth. Most of us can’t stand doing it, yet we know that the repercussions from avoiding it can be far worse. A Massachusetts dentist likely knows this analogy much more than he would like to. Earlier this year, we brought you a story about a medical doctor that was involved in tax evasion and now it seems that dentistry will get its turn.

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Credit Suisse Sentenced, Ordered to Pay over $2 Billion

Credit Suisse Sentenced, Ordered to Pay over $2 Billion

| Dec 04 | FBAR Compliance and Disclosure, Tax Law Blog | No Comments
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It is commonly said that all good things must come to an end. That seems especially true for the operations of Swiss bank Credit Suisse AG, with regards to their business practice of assisting Americans avoid U.S. income tax. Now, the Swiss mega-bank will have to pay approximately $2.1 billion to federal and state agencies as part of a sentencing order handed down in a federal court, last week. If you fail to report your foreign accounts by filing an FBAR, you could be facing harsh financial penalties, too.

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Hong Kong and the U.S. Enter Into Long-Awaited Intergovernmental Information Sharing Agreement (IGA)

Hong Kong and the U.S. Enter Into Long-Awaited Intergovernmental Information Sharing Agreement (IGA)

| Dec 02 | OVDI Program, Tax Law Blog | No Comments
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If you have been following the developments of the Foreign Account Tax Compliance Act (FATCA), you have likely observed that many U.S. trading partners were early signatories to Intergovernmental Agreements that facilitate information sharing with the United States. One of our largest trading partners and one of the world’s biggest financial hubs, Honk Kong, was one of the only countries of its influential magnitude that hadn’t entered into such an agreement. That all changed last week with the government in Hong Kong announcing their Model 2 IGA with the U.S. How could this agreement affect American taxpayers, and what do you need to know about the Offshore Voluntary Disclosure Program?

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Swiss Banker’s Acquittal Still Bad News For U.S. Taxpayers

Swiss Banker’s Acquittal Still Bad News For U.S. Taxpayers

| Nov 13 | FBAR Compliance and Disclosure, Tax Law Blog | No Comments
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It took a federal jury only 90 minutes to reach a not-guilty verdict on Monday in the case of former UBS executive Raoul Weil. The former global wealth-management chief was being tried on conspiracy charges relating to the efforts by UBS and their employees to assist U.S. taxpayers avoid declaring or paying taxes on, their accounts held outside of the U.S.  If you have accounts overseas, the time to file an FBAR is now.  Read More

Swiss Banks Ask DOJ to Ease Amnesty Requirements

Swiss Banks Ask DOJ to Ease Amnesty Requirements

| Nov 11 | OVDI Program, Tax Law Blog | No Comments
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The past few years have been rough for Swiss banks. Several banks have either pled guilty to U.S. crimes or have come to an agreement with the U.S. Department of Justice and agreed to pay fines and other penalties to avoid prosecution. Another way that Swiss banks have been ensuring that they are not criminally prosecuted in the United States is a non-prosecution program. This program provides amnesty to Swiss banks and consequently has been heavily utilized. Since its inception in 2013, approximately one-third of Swiss banks have joined. The crux of the deal is that the Department of Justice will agree to not prosecute the participating Swiss banking entities in exchange for full and total cooperation.

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Web Entrepreneur Charged Over Swiss Bank Account

Web Entrepreneur Charged Over Swiss Bank Account

| Oct 23 | OVDI Program, Tax Law Blog | No Comments
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It seems that every week, we bring you stories about United States taxpayers that have been charged with hiding money in foreign bank accounts. As of recently, taxpayers have, for the most part, shifted away from storing their money in Swiss banks. This is, in large part, due to the major crackdown of Swiss banks in an attempt by the U.S. to destroy any type of secrecy arrangements that foreign institutions may have with their customers. But alas, all of the news about prosecutions and IRS criminal investigations over stashing money in Swiss institutions doesn’t deter everyone.

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Prepare Your Offshore Disclosure Carefully — Especially Where it Involved 5 or More Foreign Informational Returns — Or Else

Prepare Your Offshore Disclosure Carefully — Especially Where it Involved 5 or More Foreign Informational Returns — Or Else

| Oct 21 | OVDI Program, Tax Law Blog | No Comments
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The IRS developed the Offshore Voluntary Disclosure Program to help taxpayers come clean about accounts held in foreign jurisdictions. Because the program is one of administrative grace and not a right of taxpayers, the Service has unfettered authority to administer it as they choose. An update of the Internal Revenue Manual (providing procedural guidance to IRS employees) sheds some light on how applications to be a part of the OVDP are selected for an examination.

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Foreign Banks Directed to Hand Over American Account Info

Foreign Banks Directed to Hand Over American Account Info

| Oct 16 | FBAR Compliance and Disclosure, Tax Law Blog | No Comments
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Orange County taxpayers haven’t been the only folks to line up to take advantage of a voluntary disclosure program offered by the government. Over 100 foreign banking institutions signed up to take part in anti-prosecution agreements with the Department of Justice earlier this year. This was, in large part, a response to the huge settlement between the DOJ and UBS, back in 2009. UBS handed over fines of roughly 780 million dollars and agreed to hand over the names and account information of tens of thousands of its American account-holders.

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