Are Quiet Disclosures of Offshore Accounts Becoming Even Riskier?

By Phil Karter Is the IRS getting closer to ferreting out “quiet disclosures” by taxpayers who chose that route to address the problem of previously unreported offshore accounts rather than by participating in the Service’s offshore voluntary disclosure program (OVDP)?  That’s the conclusion of an increasing number of tax professionals and if taxpayers in this … More Are Quiet Disclosures of Offshore Accounts Becoming Even Riskier?

Apple’s Double Irish With A Dutch Sandwich Goes Down Easy with SEC

By Phil Karter Senator Carl Levin (D-Mich.) may have tried to take a bite out of Apple (AAPL) in congressional hearings last May examining the company’s overseas tax structure, calling it “the holy grail of tax avoidance.” However, it appears that more than just Irish eyes are smiling on the company these days, for in … More Apple’s Double Irish With A Dutch Sandwich Goes Down Easy with SEC

By Appeasing the United Kingdom, Starbucks May Have Relocated Its Tax Problems Into The United States

By:  Dustin Covello As one of many U.S. multinationals that reportedly implemented the Double Irish international tax structure, Starbucks has reportedly paid a U.K. tax rate of 2.8 percent over the last decade.  Not satisfied with this levy, last month the British Parliament called Starbucks and other U.S. multinationals before the body to discuss the … More By Appeasing the United Kingdom, Starbucks May Have Relocated Its Tax Problems Into The United States

The New Duty to Report Foreign Financial Assets on Form 8938: Demystifying the Complex Rules and Severe Consequences of Noncompliance

By Hale Sheppard Concerned about the extent of international tax non-compliance, Congress enacted the Foreign Account Tax Compliance Act (“FATCA”).  Among other provisions found in FATCA was Section 6038D, which requires certain individuals to annually report to the IRS data about their interests in foreign financial assets.  Sounds simple enough, right?  Well, this seemingly straightforward … More The New Duty to Report Foreign Financial Assets on Form 8938: Demystifying the Complex Rules and Severe Consequences of Noncompliance

Detection Risk Continues To Grow As The IRS Expands Its Offshore Bank Account Investigation Into Liechtenstein

By:  Dustin Covello Late late year, we asked what’s next for foreign bank account holders after OVDI?  Although the answer to this question continues to evolve, it is becoming increasingly clear that the risks of detection have only grown – and will continue to do so.  The latest news on this front comes from Business … More Detection Risk Continues To Grow As The IRS Expands Its Offshore Bank Account Investigation Into Liechtenstein

Form 8938 – Foreign Reporting Trap for the Unwary

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.  … More Form 8938 – Foreign Reporting Trap for the Unwary

More Foreign Reporting for US Taxpayers? Absolutely says IRS

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 … More More Foreign Reporting for US Taxpayers? Absolutely says IRS