As you may have read, the Internal Revenue Service (“IRS”) recently announced changes to its offshore voluntary disclosure programs and announced new options for taxpayers to come into compliance with their U.S. tax...more
7/17/2014
/ Credit Suisse ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Actions ,
FBAR ,
IRS ,
Offshore Banks ,
Offshore Funds ,
OVDP ,
Penalties ,
Pre-Clearance ,
Tax Penalties ,
UBS
The question of who is a U.S. person has always been relevant for tax purposes because it determines who is subject to (a) U.S. income, gift and estate tax, (b) filing Foreign Bank Account Reports (FBARs), and (c) the ‘‘exit...more