Offshore Banks

News & Analysis as of

Offshore Accounts? IRS is Watching

If you have unreported income from offshore accounts, now may be the best time to come forward and report those earnings; otherwise, you may be susceptible to criminal prosecution. The IRS initially began this...more

FATCA – It’s Here, It’s Not Going To Be Delayed And Action May Be Needed By April 25, 2014. Is Your Fund Ready?

FATCA is the new form of 30% U.S. withholding tax that is applied to U.S. source income, such as interest and dividends paid by U.S. companies, starting as early as July 1, 2014 for payments made to non-U.S. entities that are...more

Senate Hearing Takes Aim on Offshore Tax Evasion

Today, February 26, 2014, the Senate Permanent Subcommittee on Investigations will hold a hearing on offshore tax evasion titled “Offshore Tax Evasion: The Effort to Collect Unpaid Taxes on Billions in Hidden Offshore...more

Increased supervision of BVI Real Estate Agents by the FIA

The BVI Financial Investigation Agency (FIA) is presently reviewing the compliance arrangements of real estate agents throughout the jurisdiction to ensure they meet the requirements of the British Virgin Islands’ (BVI)...more

6 Reasons US Taxpayers Should Report Assets Held in Swiss Banks Soon

Initial success of DOJ Swiss bank amnesty program creates greater urgency for US taxpayers. On December 31, 2013, the window to apply for the US Department of Justice’s (DOJ) amnesty program closed for certain Swiss...more

Release of Names With Interests in Offshore Entities: Ramifications

A database containing the names of more than 37,000 people with offshore entities and trusts in 10 tax haven jurisdictions was recently released online, providing a powerful investigative tool for regulators, journalists and...more

Courts are Consistently Ruling that the Act of Production Privilege Will Not Defeat Grand Jury Subpoenas Calling for Foreign Bank...

On December 13, 2013, the United States Court of Appeals for the Fourth Circuit issued its decision in United States of America v. Under Seal. On December 19, 2013, the U.S. Court of Appeals for the Second Circuit issued its...more

FBAR Update

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

FBAR E-Filing and Signature Authority: What You Need to Know

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

Federal Court Rejects Efforts to Diminish Measures Aimed at Reducing Offshore Tax Avoidance

As of January 1, 2013, United States banks were required to report to the IRS interest earned by nonresident aliens who are residents of certain foreign countries. The reporting requirement previously existed for accounts...more

Cayman Islands retain Moody's Triple A rating

The Cayman Islands Ministry of Public Finance has reported that the jurisdiction has retained its very high “Aa3” rating from Moody’s, one of the world’s foremost financial rating agencies. Cayman has held this status...more

Guide to the British Virgin Islands Approved Manager Regime

This guide provides an overview of the British Virgin Islands’ Approved Manager regime. The regime came into effect on 10 December 2012 with the Investment Business (Approved Managers) Regulations, 2012 (the “Regulations”)...more

Implications of the Foreign Account Tax Compliance Act, FATCA

Protecting domestic revenue is just one of several reasons why G-20 nations are cracking down on tax havens. Other reasons include their desire to track the international flow of funds used for terrorist activity or money...more

Raminfard Guilty Plea Highlights Complexity Of International Tax Compliance, Seriousness Of Violations, Importance Of IRS Offshore...

Los Angeles Businessman, David Raminfard, pleaded guilty on November 4th, 2013 in the Federal District Court in Los Angeles to conspiring to defraud the United States, the Justice Department and Internal Revenue...more

Cayman Islands signs FATCA Agreement with USA

Cayman Islands signed a "Model 1" intergovernmental agreement on FATCA ("IGA"). The United States considers this IGA already to be in effect, despite the need for implementing measures in the Cayman Islands. This IGA is the...more

More Swiss Banks Will Disclose/Cooperate with Offshore Tax Investigations

The U.S. Department of Justice (DOJ) offer of non-prosecution agreements to certain Swiss banks expires December 31, 2013. Swiss banks who know or suspect that they have violated U.S. law, but who are not currently the...more

American Pleads Guilty to Hiding Money in Israeli Bank Accounts

Tax Analysts Tax Notes is reporting that David Raminfard of Los Angeles pleaded guilty on November 4, 2013, in federal court to one count of conspiracy to defraud the United States (Klein conspiracy). ...more

District Court Rules for Taxpayer in STARS Case Santander Holdings; Court of Federal Claims Rules for Government in STARS Case...

In this issue: - Swiss Bank Settlement Dilemma - District Court Upholds STARS Transaction Ruling Payment Is Included in Pre-Tax Profit - Court of Federal Claims Holds for Government in BB&T STARS...more

Offshore Accounts Holders Have No Fifth Amendment Protections

In what is becoming an increasingly used attack vehicle, the Department of Justice (DoJ) is using the “required records doctrine” to compel taxpayer’s to produce what may be incriminating evidence of ownership or control of...more

Swiss Private Bank Dissolves Under Scrutiny by U.S. Department of Justice

Tax Notes reports that private Swiss bank Bank Frey & Co. AG announced October 17 that it will cease operations, further fallout from the United States’ enforcement efforts against offshore banks generally and Swiss banks in...more

Should Offshore Banks Share FBAR Penalties

Many participants in and out of the Offshore Voluntary Disclosure Program (OVDP) have concerns that the financial institutions who marketed or promoted secret account with tax evasion at its core are not paying their fair...more

Shanghai Pilot Free Trade Zone (PFTZ)

The China (Shanghai) Pilot Free Trade Zone (PFTZ) officially launched on September 29th, granting 25 Chinese and overseas companies licenses to register in the PFTZ on its first day. The General Plan for the PFTZ was...more

Arizona Businessmen Receive Lenient Sentences For Stashing Millions in Secret Swiss Accounts

Bloomberg BNA is reporting that two prominent Phoenix businessmen were each sentenced to 10 months in prison for their roles in a scheme to stash more than $8 million in secret offshore Swiss bank accounts and for not...more

Swiss Banks to Receive No Credit for Customers Who Entered OVDP without Banks' Encouragement

Tax Analysts Tax Notes reports that Kathryn Keneally, assistant attorney general for the Justice Department Tax Division, said that Swiss banks that enter the IRS’s newly-offered program will receive no credit for customers...more

The DOJ Ratchets Up Its Crackdown On Swiss Bank Accounts

In my last post, I discussed the possibility that Bitcoins and other virtual currencies could replace Swiss bank accounts as the tax havens of the future. Recent developments in the government’s war on offshore accounts...more

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