Foreign Banks Internal Revenue Service

News & Analysis as of

Singapore’s Banking Secrets - Not So Secret Anymore

Since 2008, the U.S. Government has largely focused its enforcement actions against Swiss banks that may have assisted U.S. taxpayers in evading federal taxes. In August 2013, the Department of Justice (“DOJ”) introduced the...more

US Internal Revenue Service and US Treasury Department Issue Anti-Inversion Regulations

The US Internal Revenue Service issued a proposal under Section 385 of the Internal Revenue Code with respect to the treatment of instruments issued by corporations in related-party transactions as debt or equity for federal...more

IRS Uses New Tactic to Expand Efforts to Combat Offshore Tax Evasion

In a search for financial records of a U.S. taxpayer who allegedly parked undeclared income offshore, the Internal Revenue Service (IRS) and the U.S. Department of Justice (DoJ) are seeking to enforce a summons against a U.S....more

Cross-Border Banking and Out-of-this-World Penalties - Dealing with the IRS when you have Foreign Bank Accounts

A United States citizen or resident that owns (or has signatory authority over) an account at a foreign bank with a value in excess of $10,000 annually must file a Report of Foreign Bank and Financial Account (or “FBAR”) with...more

Global Tax Enforcement in 2016: What You Need to Know

The investigation and prosecution of tax evasion has, in the past decade, grown from a specialized subcategory of law enforcement into a first-tier policy concern for the international community. Financial institutions,...more

FATCA Update: Treasury Relaxes September 30 Deadline for Model 1 IGA Jurisdictions to Exchange Tax Information

With less than two weeks remaining until many countries are required to exchange tax information with the U.S. pursuant to the Foreign Account Tax Compliance Act (FATCA), the U.S. has agreed to provide partner jurisdictions...more

Bad Bad, Bad Penalty, Bad OVDP Policy

There are now 50 foreign financial institutions on the IRS list of "bad banks" The list is published at the following link...more

Two More Banks Reach Resolutions Under Justice Department’s Swiss Bank Program

On June 3, 2015, the Justice Department announced that two more Swiss banks, Rothschild Bank AG and Banca Credinvest SA, reached resolutions under the DOJ Swiss Bank Program. Yesterday’s announcement brings the total Swiss...more

What To Do If You Have Delinquent International Information Tax Returns

A U.S. taxpayer with international holdings and interests may not be fully compliant with U.S. tax reporting obligations even though they have currently reported all foreign source income on their annual tax return, filed...more

Foreign Account Holders: Don’t Forget to File Your FBARs by the June 30th Deadline

Now that the April 15th deadline has passed and tax season is over, most taxpayers can breathe a sigh of relief. At least for another year. For others with overseas financial accounts and interests, one more reporting hurdle...more

Foreign Banks and Bankers Face New Risks From Swiss Bank Amnesty

The first non-prosecution agreement signals expanded US tax enforcement opportunities at home and abroad. The US Department of Justice (DOJ) has announced the first non-prosecution agreement (NPA) with BSI, SA, (BSI)...more

Dealing with Erroneous FATCA Inquiries

A foreign bank asks our client to provide information that the bank is not required to provide IRS under FATCA. There are two possibilities. Our client can provide the information or our client can choose not to provide the...more

FATCA Notebook: Former IRS Chief, Taxpayer Advocate Criticize FATCA; Switzerland Moves Toward Greater Transparency

First, former acting IRS Commissioner Steven Miller speaks out against FATCA and suggests that the benefits of the new information reporting regime imposed by FATCA may not outweigh its costs. An article published by...more

Offshore Tax Enforcement Update: IRS Unveils Major Changes to Voluntary Disclosure Program

Since the 1970s, U.S. taxpayers with foreign banks accounts have been required to annually report their foreign bank account information to the Department of Treasury on a Report of Foreign Bank and Financial Accounts...more

June 30 Deadline Approaches for Mandatory E-File FBAR Reporting

2014 presents particular challenges with respect to FBAR, the Report of Foreign Bank and Financial Accounts, for certain U.S. persons with interests in or signature authority over assets exceeding $10,000 held outside the...more

Bitcoin Reportability and Taxation

June 30 is the deadline for taxpayers with a connection to foreign financial accounts to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR). As this is the first year in which all FBARs must be...more

DOJ Secures Verdict in Excess of $2 Million for Failure to File FBARs

On Wednesday, May 28, 2014, a jury in Miami issued a verdict against a taxpayer for $2.2 million in fees, interest, and civil penalties for willfully failing to file foreign bank account reports (FBARs) for his Swiss bank...more

FBAR Penalty to Face Excessive Fines Clause Test

Last week, a federal jury in Miami found that Carl Zwerner had willfully failed to disclose his foreign bank account to the Treasury Department for calendar years 2004, 2005 and 2006. Zwerner now potentially owes the United...more

The Taxman Cometh for US Holders of Foreign Bank Accounts

U.S. citizens and residents with unreported assets abroad may be feeling a steady increase of pressure these days. The July 1, 2014 effective date of the Foreign Assets Tax Compliance Act (FATCA) is looming. The number of...more

DOJ Offshore Enforcement Update: In Landmark Case, Credit Suisse Pleads Guilty, Agrees to Pay $2.6 Billion Penalty; Swiss Bank...

Yesterday, the Department of Justice announced that Credit Suisse AG pleaded guilty to having assisted U.S. taxpayers in evading the payment of U.S. taxes and agreed to pay a penalty of $2.6 billion. Deputy Attorney General...more

IRS Announces Transitional Period for FATCA Enforcement, Other FATCA Rule Changes

The IRS notice further eases, but does not delay, FATCA implementation. On May 2, the Internal Revenue Service (IRS) published Notice 2014-33 (the Notice), which announced that calendar years 2014 and 2015 will be...more

Focus on Tax Controversy and Litigation - Supreme Court Decides Woods v. Commissioner, Holds for IRS on Jurisdictional and...

In this issue: - US Supreme Court Imposes Valuation-Misstatement Penalty in TEFRA Proceeding - Southern District of New York holds Cooperation with Government Waives Attorney-Client Privilege - IRS Issues...more

IRS Extends FATCA Registration Deadline to May 5, 2014

HIGHLIGHTS: - Foreign financial institutions must perform due diligence to identify their U.S.-owned accounts and report them to the IRS, as well as act as a withholding agent for payments to other foreign entities....more

Update: U.S. International Tax Enforcement Efforts

On February 25, 2014 the U.S. Senate Permanent Subcommittee on Investigations, issued its report on its investigation into offshore tax evasion and the participation of Swiss Banks. Specific recommendations were made, among...more

Corporate and Financial Weekly Digest - Volume IX, Issue 8

In this issue: - OTC Markets Proposes Amendments to OTCQX Rules and New Rules for US Banks - SEC Approves Changes to FINRA BrokerCheck Disclosure Rule 8312 - SEC to Examine Never-Before Examined...more

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