IRS Reporting / Offshore & Foreign Compliance

It is legal for U.S. taxpayers (including green-card holders) to have foreign bank accounts, own or invest in offshore real estate and/or businesses. There are many legal reasons for a U.S. taxpayer to do so, including, but not limited to, for confidentiality purposes, investment purposes, requirements of a foreign government, and asset protection.

However, the U.S. has complicated reporting requirements for offshore bank accounts and assets, including but not limited to: foreign bank accounts, online gambling accounts, passive foreign investment companies, investments in foreign mutual funds, foreign trusts, and other areas.

For years, numerous taxpayers holding offshore or foreign bank accounts or having offshore income have not disclosed the existence of these accounts or claimed income from them on their income tax returns. These taxpayers thought that the U.S. government could not obtain information about their accounts.

THINGS HAVE CHANGED.

The United States is NOW enforcing a global taxation strategy by efforts such as Foreign Account Transaction Compliance Act (FATCA) and activity targeting U.S. taxpayers with Offshore Bank Accounts and Investment account holders both civilly and criminally.

At, Moskowitz LLP, we have a comprehensive understanding of the tax laws and policies that affect people with money, assets in business and investments in the United States and overseas. We have helped hundreds of offshore account holders and investors, since the enforcement programs began alone; find out how we can help you:

Offshore & Foreign Compliance Resource Information:

Enforcement News

A. Criminal Prosecutions:

i. Banks

• U.S. investigation of HSBC
• U.S. investigation of Swiss banking giant UBS
• German investigation of Credit Suisse
• Weglin

ii. Promoters
iii. Individuals

B. Civil Enforcement

Policy Notes & Legislation
Avoid Criminal Prosecution

• What is a criminal prosecution
• Criminal Investigations
• Civil Investigations that go Criminal
• Criminal Penalties
• Statute of Limitations
  • Tolling Event

Voluntary Disclosure for Offshore Bank Accounts, failure to report FBAR

• Offshore Voluntary Disclosure Program (OVDP)
• Prior Programs
• OVDI 2009, OVDI 2011
• Opting Out
• Quiet Disclosure / Explained Disclosure

Civil Tax & FBAR Penalties

• Civil fraud
• Unlimited statute of limitations and the civil fraud penalty
• Willfulness penalty
• Non-willful penalty
• Collection of Penalties
  

Also See: Offshore Banking, Offshore Planning, Foreign Bank Account Representation, Offshore Voluntary Disclosure, California Voluntary Disclosure Initiative, Foreign Account Tax Compliance Act (FATCA), Passive Foreign Investment Companies, QEF Elections, Making a Mark-to-Market Election, Controlled Foreign Corporations,