Archive for the ‘Individual’ category
April 11, 2012
By Sebastien Chain and Tamara Woods Beginning with the 2011 tax year (i.e., for returns filed April 17, 2012 or later), individual taxpayers will be required to file Form 8938 if he or she has an interest in a “specified foreign financial asset” (“SFFA”) (click for additional information on FATCA requirements) that has a value exceeding a certain threshold. [...]
Categories: Individual, International
Tags: FBAR, Foreign Assets, Form 8938, International
Comments: 1 Comment
April 3, 2012
By Sebastien Chain and Tamara Woods The Hiring Incentives to Restore Employment Act of 2010 (“HIRE Act”) enacted the Foreign Account Tax Compliance Act (“FATCA”). P.L. 111-47. FATCA greatly increases disclosure requirements and penalties on taxpayers with foreign accounts and assets. These reporting requirements will affect individuals beginning with the 2011 tax year, and are expected [...]
Categories: Individual, International
Tags: FBAR, Foreign Assets, Form 8938, International
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March 9, 2012
By Hale Sheppard Life grants few chances at true redemption. The Internal Revenue Code, likewise, is not known for facilitating taxpayer salvation. Sure, under certain circumstances, taxpayers have an opportunity to file late tax-related elections to rectify an oversight, and other forms of clemency exist. However, the general rule is that taxpayers are stuck with [...]
Categories: Administrative, Individual
Tags: Penalties, qualified amended returns, Tax Court, tax position
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January 25, 2012
By Jonathan Prokup and Dustin Covello Following the release of Ann and Mitt Romney’s tax returns, the news media and political commentators of all stripes have – to paraphrase Arlo Guthrie – detected, neglected, selected, rejected, and inspected those returns for a variety of commercial and political purposes. As expected, the return shows substantial income, [...]
Categories: Administrative, Individual, International
Tags: FBAR, foreign investment, Mitt Romney, offshore bank accounts, OVDI, Penalties, PFIC
Comments: 1 Comment
January 10, 2012
By Jonathan Prokup and Dustin Covello The IRS announced yesterday a reopening of its 2011 offshore voluntary disclosure initiative (“OVDI”). This program will have essentially the same terms as the 2011 OVDI, but with a penalty rate of 27.5 percent (rather than 25 percent) of the highest account balance during the period covered by the [...]
Categories: Administrative, Individual, International
Tags: Credit Suisse, FBAR, HSBC, offshoare bank accounts, OVDI, Penalties, Swiss, tax evasion
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December 7, 2011
By Jonathan Prokup Peter Pappas at the Tax Lawyer’s Blog takes note of a recent report from TIGTA regarding audits of small corporations (those with less than $10 million in assets, according to the IRS). As Mr. Pappas says, language from the report suggests that Treasury may consider the closely held nature of many small [...]
Categories: Administrative, Corporate, Individual
Tags: Audit, closely held business, Global High Wealth Industry Group, IRS, schedule utp, tax gap
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December 5, 2011
By Jonathan Prokup Over the weekend, a variety of Canadian news sources (see, e.g., the Financial Post and the Edmonton Journal) reported on anticipated guidance from the IRS, which would result in the waiver of penalties on certain U.S. citizens living in Canada for past failures to file Form TD F 90-22.1, commonly known as [...]
Categories: Administrative, Individual, International
Tags: bank accounts, Canada, disclosure, FBAR, IRS, OVDI
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December 2, 2011
By Jonathan Prokup For taxpayers who entered the IRS’s second Offshore Voluntary Disclosure Initiative (“OVDI”) prior to August 31, 2011, November 29th marked the end of the extended deadline that some taxpayers requested for submitting all of the materials included in the disclosure (e.g., amended returns, FBARs). Coincidentally with the timing of this deadline, many [...]
Categories: Administrative, Corporate, Individual, International
Tags: bank account, FBAR, IRS, noisy disclosure, OVDI, Penalties, quiet disclosure
Comments: 7 Comments
May 23, 2011
By Jonathan Prokup As part of its current Offshore Voluntary Disclosure Initiative (“OVDI”), the IRS is strongly encouraging taxpayers against making so-called “quiet” disclosures, in which taxpayers file amended tax returns, pay the applicable taxes and interest, and hope that the IRS doesn’t identify them for further investigation. These disclosures are described as quiet because [...]
Categories: Corporate, Individual, International
Tags: bank accounts, HSBC, offshore, OVDI, Penalties
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April 14, 2011
By Jonathan Prokup Last week, the United States Department of Justice asked a federal court in San Francisco to force HSBC India to disclose the names of U.S. customers whom the Justice Department suspects are evading U.S. tax laws. According to the Justice Department’s brief, HSBC India solicited U.S. residents of Indian origin to open [...]
Categories: Administrative, Corporate, Individual, International
Tags: FBAR, foreign bank accounts, HSBC, India, OVDI, Penalties
Comments: 1 Comment
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Phil Karter
Jonathan Prokup
David Shakow
George Connelly, Jr.
Buck Buchanan
David Bernard
Dustin Covello
Heather Pesikoff
Hale Sheppard
dustincovello
