News & Analysis as of

Offshore Funds

IRS Signals Intent to Aggressively Pursue Undisclosed Offshore Accounts

by Varnum LLP on

At the recent National Institute on Criminal Tax Fraud and Tax Controversy, senior IRS and Department of Justice (Tax) officials sounded the proverbial warning alarm to taxpayers with undisclosed or offshore financial...more

DOJ Announces Major New Shift in Criminal Sentencing in Offshore Tax Matters

At the 34th Annual National Institute on Criminal Tax Fraud in Las Vegas yesterday afternoon, Mark Daly, DOJ Tax Division Senior Litigation Counsel announced a major new shift in how the Department of Justice plans to argue...more

Did The Paradise Papers And Panama Papers Play A Role In The GOP Tax Plan?

by Ifrah PLLC on

Congress is poised to deliver on tax reform this year. As part of the package, both houses are seeking to encourage the repatriation of trillions of dollars that corporations and wealthy individuals have been stockpiling...more

Paradise Papers: The Latest Offshore Leak

by Jones Day on

Hackers leaked approximately 13.4 million confidential client documents from Appleby, Estera, and Asiaciti Trust to the International Consortium of Investigative Journalists....more

Senator Rand Paul Once Again Takes Aim At FATCA

by Fox Rothschild LLP on

In the midst of the tax reform debate currently embroiling Congress, Senator Rand Paul (R-Kentucky) has introduced an amendment seeking to repeal the Foreign Account Tax Compliance Act (FATCA), an anti-tax evasion law enacted...more

Infamy and Public Shaming: The newest risk of using "offshore" entities - What investors, companies and high-net-worth...

by Dentons on

While many companies and businesspeople actively manage their online and social media presence – many overlook the reputational impact of their financial and tax planning decisions. The recent “Paradise Papers” leak...more

Notes on the Financial Surveillance Special Voluntary Disclosure Programme process

by Hogan Lovells on

The Financial Surveillance Special Voluntary Disclosure Programme (the FinSurv SVDP) was announced by the Minister of Finance in the February 2016 Budget Speech....more

The Accountant and the Paradise Papers

by Foodman CPAs & Advisors on

Under U.S. Tax Law, it is appropriate for an Accountant to advise a US Taxpayer regarding his tax efficiency if the Taxpayer wants to pay less tax and accumulate wealth. While tax avoidance is legal and encouraged by the...more

On Eve Of “Paradise Papers” Release, At-Risk Individuals Should Consider Immediate Action To Mitigate Potential For Criminal...

by Fox Rothschild LLP on

Tomorrow morning (November 17) the International Consortium of Investigative Journalists (ICIJ) is set to release publicly the first set of comprehensive data from the recent “Paradise Papers” leak. The initial data will...more

Offshore Assets May Be Subject to Enforced Collection by the IRS

by Sanford Millar on

The fact that you may have assets offshore does not mean that they are immune from seizure by the IRS. A recent case illustrates how the IRS can enforce collection outside the United States....more

Manafort Indictment Alleges High-End International Money Laundering and Tax Fraud Involving Offshore Accounts

by Ballard Spahr LLP on

As the world now knows, an indictment against Paul Manafort, Jr., a former campaign chairperson for now-President Donald Trump, and Manafort’s associate, Richard Gates III, was unsealed yesterday. ...more

Money Laundering Watchdog Criticizes Lax AML Enforcement and “Creative Compliance” in Wake of Panama Papers

by Ballard Spahr LLP on

PANA Issues Recommendations to European Parliament: Tougher Enforcement, Greater Transparency, Improved Information Sharing and Prohibitions Against Outsourcing of Customer Due Diligence....more

No Rest For The Weary: Offshore Tax Evasion Crackdown Continues With Flurry Of Mid-Summer Activity

by Fox Rothschild LLP on

Dashing any thought that they were taking a hiatus from investigating and prosecuting taxpayers with secret offshore bank accounts and the bankers that helped them, the Justice Department and Internal Revenue Service have...more

Overview of IRS Penalties for Individuals with Foreign Bank Accounts and Investments

by Blank Rome LLP on

Earlier this spring, the Internal Revenue Service ("IRS") Large Business and International Division identified several "campaigns" or areas where it plans to focus its audit resources. One campaign involved taxpayers who...more

FBAR Penalties Now Adjusted for Inflation: Abatement/Mitigation Still Possible

If you haven’t filed your Report of Foreign Bank and Financial Accounts (FBARs) on a timely basis, you could be at risk of a higher civil penalty assessment. Inflation-adjusted FBAR penalties are now in effect....more

2017 OVDP Declines and Withdrawals Campaign: Certain U.S. Taxpayers at Risk of Audit

In 2016, the Treasury Inspector General for Tax Administration (TIGTA) released a report which assessed how well that IRS was managing the Offshore Voluntary Disclosure Program (OVDP). OVDP is one of the programs taxpayers...more

Applying Overpayments of Tax to Tax and the Offshore Penalty in the OVDP Program

by Charles (Chuck) Rubin on

The OVDP program allows taxpayers to remedy deficient disclosure filings relating to offshore accounts for a fixed penalty amount. As part of the program, taxpayers must file either original or amended tax returns which...more

Lawyers as “Gate Keepers” – The European Parliament Examines the Roles of Attorneys in Tax Evasion and Laundering Schemes

by Ballard Spahr LLP on

Starting on April 27, and finishing on May 2, the European Parliament (EP)’s Committee of Inquiry into Money Laundering, Tax Avoidance and Tax Evasion (PANA) is holding two meetings to present several related studies which...more

Debit cards, Offshore Funds and a John Doe Summons

by Foodman CPAs & Advisors on

IRS remains committed to its priority efforts to stop offshore tax evasion wherever it occurs. It pursues cases in all jurisdictions of the world. Over the years, numerous individuals have been identified as evading US...more

New Due Date for “FBAR” Filings - Report of Foreign Bank and Financial Accounts now due on Tax Day, with auto-extension for six...

Federal law requires U.S. citizens and resident aliens to report world-wide income, including income from foreign trusts, bank and securities accounts. In addition to attaching Schedule B to their tax returns disclosing...more

On the Eve of Tax Day, Justice Department Warns That Tax Evaders Will Face Prison Time

by Fox Rothschild LLP on

With only four days remaining until “Tax Day,” the Justice Department’s well-publicized campaign to deter potential tax evaders continues with more stern warnings to taxpayers. In a bleak press release entitled “With the...more

Choose Opt Out Option Wisely in Offshore Voluntary Disclosure Program

Since 2009, the Internal Revenue Service has offered a variety of offshore voluntary disclosure programs (collectively, OVDP) under which a U.S. taxpayer can disclose previously undisclosed offshore activities. However, these...more

Tax Round Up - April 2017

by Proskauer Rose LLP on

Welcome to the Tax Round Up, the first edition of what will be a regular bulletin highlighting the latest tax developments relevant to UK companies and asset managers. We plan to produce this monthly with the next one in...more

Getting Into Compliance with Your Foreign Account Reporting, Part II

by Moskowitz LLP on

In Part I, we listed some of the penalties associated with the failure to report foreign accounts, and what is widely regarded as the best option for coming into compliance – the Offshore Voluntary Disclosure Program (OVDP)....more

Getting Into Compliance with Your Foreign Account Reporting, Part I

by Moskowitz LLP on

With the 2015 release of the “Panama Papers,” roughly 11.5 million documents detailing personal financial information of wealthy individuals and identifying nearly 215,000 offshore entities are now available to government...more

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