The past few months have been filled with contention from the Swiss government and UBS in response to the Internal Revenue Service’s (IRS) “John Doe Summons,” which seeks to have UBS turn over the names of their US account holders. So far, UBS has been unwilling to provide the names…
When the Internal Revenue Service (IRS) released its FBAR tax amnesty FAQs it stated that there would be no standard list of questions asked of foreign bank account holders who made a voluntary disclosure. The Wall Street Journal reported that at least one tax attorney has stated that his clients…
The hearing on the tax fraud through the use of tax fraud. Generally, under the terms of the existing treaty with Switzerland, the IRS must have evidence of tax evasion before the Swiss will turn over Swiss bank accounts at UBS. According to offshore financial account must report that TD…
The Swiss government has threatened to seize UBS summons lawsuit pending in District Court in Miami, Florida. Does this mean that U.S. taxpayers who have tax fraud or John Doe summons case there are numerous other ways it can come to the attention of the IRS. For example, most offshore…
I have been speaking a lot lately to the Internal Revenue Service’s (IRS) tax amnesty hotline to obtain answers to the many practical questions that have arisen under the IRS Tax Amnesty a.k.a. tax amnesty program take place?” The agent that I spoke with at the tax audits will be…
The IRS has just issued new FAQs related to the Foreign Bank Account Reports (FBAR). There are 21 new offshore financial account penalty as part of the FBAR prior post. If the taxpayer disagrees with the imposition of the penalties then the taxpayer may go to the IRS Appeals Division.…
The U.S. Treasury has announced an agreement with Switzerland to amend the Swiss U.S tax treaty to allow the U.S. to more easily locate those engaged in tax fraud and tax evasion. The Swiss – U.S. treaty would be amended to comply with Article 26 of the Organization for Economic…
In an address to the Organization for Economic Co-Operation and Development (OECD) on June 2, 2009, IRS Commissioner Douglas Shulman announced renewed IRS efforts to combat international tax fraud and tax evasion. Shulman promised to create an inhospitable climate for tax evasion and offshore secrecy by continuing and expanding cooperation…
The Internal Revenue Service (IRS) has issued FAQs related to its offshore tax amnesty. As I have previously documented on March 23rd, the IRS announced a “tax amnesty” for owners of Swiss and other offshore accounts who failed to file TDF 90-22.1 (Report of Foreign Bank and Financial Account) a/k/a…
According to a report on Reuters, UK, Manhattan District Attorney Robert Morgenthau said New York State investigators are looking for more cases like the one in which London-headquartered Llyods agreed in January to forfeit $350 million to the United States and New York in connection with faking records related to…