Penalties associated with failing to disclose Foreign Bank Accounts

Posted on by Moskowitz LLP Posted in International Taxation
Can the IRS Automatically Assess a Penalty against a U.S. Taxpayer who Innocently or Mistakenly Failed to Disclose a Foreign Bank Account? What happens in cases where a U.S. taxpayer innocently or mistakenly failed to disclose a foreign account and mistakenly failed to report foreign source income? Is such a taxpayer doomed to pay the…
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HSBC Offshore Accounts Targeted

Posted on by Moskowitz LLP Posted in International Taxation
IRS TARGETS HSBC Recently, the Justice Department requested a federal court to force the London-based bank, Hongkong and Shanghai Banking Corporation (HSBC), to disclose the names of account holders who they suspect are evading taxes by hiding their money in offshore accounts in India. The Justice Department wants information regarding 9,000 U.S. residents holding high-value…
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California Offshore Voluntary Disclosure – New Voluntary Compliance Initiative for California

Posted on by Moskowitz LLP Posted in State & Local Taxation
In March 2011, California passed legislation to allow a program similar to the federal 2011 Offshore Voluntary Disclosure Initiative (OVDI). Senate Bill 86 was passed by the California legislature, signed by Governor Brown, and entered into California law.  While SB 86 amends several sections of the Revenue and Taxation Code, one important change is the…
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IRS Dishes out $4.5 Million Whistleblower Award to CPA

Posted on by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection, Tax Planning & Compliance
Last week, the IRS awarded a check for $3.24 million to a small-town CPA as payment under the tax whistleblower program. The check represents an award of $4.5 million with about 28 percent withheld for taxes. While the whistleblower remains unidentified, his attorney Eric L. Young, from the law firm of Egan Young in Pennsylvania,…
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U.S. Department of Justice and the Internal Revenue Service Expand Collection Efforts Internationally

Posted on by Moskowitz LLP Posted in Tax: Audits, Litigation & Collection, International Taxation, Tax Planning & Compliance
As individuals and companies take advantage of international tax benefits or previously undetected avenues of sheltering money from taxes and creditors, the Internal Revenue Service (IRS) is now concentrating more of its efforts on overseas tax compliance and collection. IRS Commissioner Douglas H. Shulman called global tax administration efforts a "critical area for our nation,"…
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2011 Voluntary Disclosure Initiative (OVDI) for Unreported Offshore Accounts

Posted on by Moskowitz LLP Posted in Criminal Tax Law, International Taxation
There has recently been a flurry of press surrounding the IRS' announcement of a new 2011 Voluntary Disclosure Initiative (OVDI) for offshore accounts. This program is part of the Department of Justice's targeting of offshore bank account holders who fail to report income associated with the account on their U.S. tax returns or fail to…
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