Entries by Tax Attorney

Do I need to file Form 8938, “Statement of Specified Foreign Financial Assets”?

In an effort to combat taxpayers who are not reporting income earned on foreign assets, the IRS has implemented a new Form 8938, Statement of Specified Foreign Financial Assets, that beginning with the 2011 tax year must be included with a taxpayer’s Form 1040 if the taxpayer holds specified foreign financial assets with an aggregate […]

U.S. Taxpayers Owning An Interest In A Foreign Entity

A U.S. taxpayer who holds an interest in a foreign entity may not realize that he or she must comply with complex tax reporting requirements as a result of holding an interest in the foreign entity.  First, a U.S. taxpayer who is a shareholder of a “controlled foreign corporation” (CFC), as defined in 26 U.S.C. […]

Court Authorizes IRS to Issue Summonses for Records Relating to U.S. Taxpayers with Offshore Bank Accounts

A number of U.S. taxpayers with beneficial ownership and control over funds held in accounts at Zurcher Kantonalbank and its affiliates (collectively, ZKB) in Switzerland, and The Bank of N.T. Butterfield & Son Limited and its affiliates (collectively, Butterfield) in the Bahamas, Barbados, Cayman Islands, Guernsey, Hong Kong, Malta, Switzerland, and the United Kingdom, have […]

HSBC Clients With Asian Accounts Said to Face U.S. Tax Probe

The Justice Department is conducting a criminal investigation of HSBC Holdings Plc clients who may have failed to disclose accounts in India or Singapore to the IRS.  Already some U.S. taxpayers have received a letter from the Justice Department that said prosecutors had “reason to believe that you had an interest in a financial account in India […]

Tax Return Preparers Face IRS Scrutiny and Criminal Prosecution for Assisting in Income Tax Evasion By Not Disclosing Clients’ Foreign Income And Foreign Accounts.

The U.S. tax laws require that U.S. taxpayers must report their worldwide income, regardless of whether they are living in the U.S. or abroad.  In addition all U.S. taxpayers who have an interest in, or signatory or other authority over a bank, securities or other similar foreign accounts must file FinCEN Form 114, Report of […]

IRS Announces New Initiative To Target Unreported Indian Accounts In Northern California

Late last year at a California Bar conference, an IRS official stated that the IRS will start in 2014 a new Indian initiative targeted at individuals with undeclared Indian accounts. Nicholas Connors, a supervisory revenue agent with the IRS small business/self employed division stated that the IRS will soon “begin examining US taxpayers suspected of holding undeclared accounts […]

Credit Suisse Helped Wealthy Americans Cheat The IRS

A Senate Report just issued states that Swiss banking giant Credit ­Suisse helped wealthy Americans hide billions of dollars from U.S. tax collectors. Credit Suisse chief executive Brady W. Dougan and Deputy Attorney General James M. Cole recently appeared at a Congressional subcommittee following the issuance of the 175-page report.  The report was issued after […]

Ten Reasons Against Continued Non-Disclosure Of Your Foreign Income And Foreign Accounts.

As an incentive to drive taxpayers into the Offshore VoluntaryDisclosure Initiative (OVDI) the U.S. government continues to ramp up its efforts in searching for and flushing out income tax evaders who continue to utilize undisclosed foreign accounts, entities or assets to hide income. Because the IRS has devoted massive resources to publicizing the reporting requirements […]