Entries by Tax Attorney

Disclosing Foreign Accounts Through the Offshore Voluntary Disclosure Initiative

IRS has established programs for taxpayers to voluntarily come forward and disclose unreported foreign income and foreign accounts under what the IRS calls the Offshore Voluntary Disclosure Initiative (OVDI). On January 9, 2012 the IRS announced the terms of the 2012 OVDI which requires that taxpayers: (1) File 8 years of back tax returns reflecting […]

IRS Processing Information Reported by Foreign Banks of their U.S. Accountholders

The Department of Justice started pressuring Swiss Banks including UBS and Credit Suisse to reveal bank account information on their account holders who are U.S. citizens or U.S. residents. Information from the Swiss Banks and other European Banks has now been flowing to IRS and is being used by IRS to uncover taxpayers who have […]

Reporting Foreign Bank Accounts to IRS

The Bank Secrecy Act requires that a Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), be filed if the aggregate balances of such foreign accounts exceed $10,000 at any time during the year. This form is used as part of the IRS’s enforcement initiative against abusive offshore transactions and attempts by […]

IRS Enforcement Action to Combat Offshore Tax Evasion

In his closing remarks, IRS Commissioner Doug Shulman affirmed that the IRS has significantly increased its resources and focus on offshore tax evasion. Since 2009 IRS gave taxpayers a chance to come in voluntarily and avoid going to jail. With the IRS’ mining of information it has received over the last few years, the IRS […]

U.S. Treasury Closer To Inking Foreign Tax Info-Sharing Deals

U.S. tax authorities and foreign governments are on track to conclude dozens of agreements in coming months on the sharing of financial data about citizens, with deadlines nearing for implementation of a sweeping U.S. anti-tax evasion law – the Foreign Account Tax Compliance Act (FATCA). More than 50 other countries are working with the IRS […]