The attorney-client privilege is one of the bedrocks of the legal profession. It permits communications between a client and an attorney to remain privileged. The U.S. Supreme Court has stated that by assuring...more
The IRS currently offers the following five programs for noncompliant taxpayers: (i) the Offshore Voluntary Disclosure Program (OVDP), (ii) Streamlined Domestic Offshore Procedures, (iii) Streamlined Foreign Offshore...more
12/24/2016
/ Bad Boy Liability ,
Criminal Conspiracy ,
Criminal Investigations ,
Delinquent Filer Voluntary Compliance ,
Expatriates ,
False-Certification of Conformance ,
FATCA ,
FBAR ,
Foreign Financial Accounts ,
Foreign Financial Institutions (FFI) ,
Guilty Pleas ,
International Consortium of Investigative Journalists (ICIJ) ,
IRS ,
OVDP ,
Panama Papers ,
Swiss Banks ,
Tax Evasion ,
Tax Fraud ,
Tax Penalties ,
Whistleblowers
According to the Miriam Webster dictionary, credibility is defined as "the quality or power of inspiring belief." When IRS Commissioner John Koskinen took office, one of his many roles involved trying to restore the integrity...more
There are a multitude of information returns that United States taxpayers may need to file if they own foreign assets or have foreign investments. Two of these forms are the FBAR (Foreign Bank Account Report) and Form 8938...more
The Report of Foreign Bank and Financial Accounts (FBAR) can no longer be filed on TDF 90-22.1, and must be e-filed on Form 114. This alert summarizes developments involving FBAR e-filing and signature authority. They are...more
1/29/2014
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
FBAR ,
FinCEN ,
Foreign Banks ,
Foreign Investment ,
IRS ,
Offshore Banks ,
Offshore Funds ,
Reporting Requirements
Much has been written about the IRS's dogged pursuit of taxpayers with unreported foreign accounts. These accounts are reported on the Report of Foreign Bank and Financial Accounts (FBAR) when a taxpayer has a financial...more