History of the Internal Revenue Service’s Voluntary Disclosure Program

This is a two-part blog post on the evolution of IRS voluntary disclosure programs.  The first post traces these programs from their inception through the 1990's.  The second post discusses the programs beginning in 2000 and carrying through to the present day. Overview Since the Justice Department sued UBS in...

IN 2010 -THE WORLD BECOMES SMALLER AND IS NOW TAX TRANSPARENT

INTERNATIONAL TAX PREPARATION FOR BUSINESSES AND INDIVIDUALS On March 18, 2010, the Foreign Account Tax Compliance Act (FATCA) was enacted into law. The scope of FATCA is extremely broad. Almost every foreign financial institution is within reach of this new law.  FATCA requires any foreign financial institution that holds any...

White Collar Crime, Structuring

Federal law requires business and financial institutions to report currency transactions in excess of $10,000 in a single or “related” transaction within a twelve-month period. Businesses must file an IRS form 8300 and financial institutions must file a currency transaction report. Even though making a deposit or withdrawal greater than...