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, [...]
Posted tagged ‘FBAR’
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The Romneys’ Tax Returns: Have FBARs Been Filed, Or Is Romney An OVDI “Candidate”?
January 25, 2012Categories: Administrative, Individual, International
Tags: FBAR, foreign investment, Mitt Romney, offshore bank accounts, OVDI, Penalties, PFIC
Comments: 1 Comment
Fox Business Interview: OVDI, FBARs, And The Economic Benefits Of A Repatriation Holiday
January 17, 2012By Jonathan Prokup Fox Business invited me to appear yesterday on “After The Bell” with Liz Claman and David Asman to discuss (i) the IRS reopening the disclosure initiative for offshore bank accounts and (ii) the ongoing debate about whether Congress should implement a corporate repatriation holiday. A link to the video is below the [...]
Categories: Administrative, International
Tags: FBAR, IRS, job creation, offshore bank accounts, OVDI, repatriation, stimulus, Taxes
Comments: 1 Comment
IRS Reopens Offshore Voluntary Disclosure Initiative (OVDI) For Delinquent FBAR Filers: 27.5 Percent Penalty
January 10, 2012By 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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Good News For Bank Account Disclosures By U.S. Citizens Residing In Canada
December 5, 2011By 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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After OVDI: What’s Next For Disclosures Of Foreign Bank Accounts?
December 2, 2011By 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: 2 Comments
Going Quietly Into The Night May Not Be The Best Idea For U.S. Citizens Living Abroad
August 26, 2011Apparently, there are a large number of U.S. citizens living outside the United States as well as a large number of individuals who are dual citizens of the United States and their country of residence (estimated to be in the millions). Judging from the phone calls that I have been receiving from my contacts at foreign [...]
Categories: Administrative, International
Tags: FBAR, foreign bank accounts, OVDI, tax evasion
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Alphabet Soup: HSBC, FBAR, And OVDI (Offshore Voluntary Disclosure Initiative) For Foreign Bank Accounts
April 14, 2011By 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
Where There’s No Will, There’s a Way to Avoid FBAR Penalties
March 15, 2011By Hale Sheppard Nowadays, newspapers and tax journals often contain articles about international tax issues, particularly the duty of U.S. persons to file an annual Form TD F 90-22.1 (“FBAR”) to report their interests in foreign financial accounts. As general knowledge of the FBAR increases, the chances of taxpayers avoiding penalties on grounds that they [...]
Categories: Administrative, Individual, International
Tags: FBAR, Penalties
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IRS Giveth and DOJ Taketh Away: Recent Opinion Jeopardizes Retroactive FBAR Relief
March 8, 2011By Hale Sheppard Much confusion has existed over the past few years about filing Form TD F 90-22.1 (“FBAR”) to report foreign accounts to the IRS. To remedy this, the IRS issued pronouncements in 2009 and 2010 granting certain FBAR filing exemptions and penalty waivers. Many of these benefits had retroactive effect. A recent criminal [...]
Categories: Administrative, Audit, Corporate, Individual, International
Tags: FBAR, foreign bank accounts
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What’s The Big Deal About Foreign Bank Accounts?
June 7, 2010By George W. Connelly Anyone paying attention to the media for the last month or so must be aware of the battle the IRS has waged with UBS in order to obtain information about owners of heretofore “secret” accounts in Switzerland. This is part of an IRS effort to track down tax delinquents who are using [...]
Categories: Uncategorized
Tags: compliance, FBAR, international tax, Swiss bank accounts, tax havens
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Phil Karter
Jonathan Prokup
David Shakow
George Connelly, Jr.
Buck Buchanan
David Bernard
Dustin Covello
Heather Pesikoff
Hale Sheppard
