Offshore Accounts

OVDP and offshore reporting

The OVDP and Offshore Reporting Requirements

It’s already understood that the failure to disclose foreign accounts can result in significant penalties. Yet while offshore enforcement concerning foreign accounts was significantly stepped up in 2009, many individuals failed to participate in the IRS Offshore Voluntary Disclosure Program (OVDP). In prior posts, we discussed the tools the IRS has at its disposal make …

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reporting offshore accounts

Reporting on Offshore Accounts

As we’ve indicated many times on this blog, there are significant disclosure requirements concerning offshore accounts and income. The Foreign Account Tax Compliance Act (FATCA) requires offshore financial institutions to either report accountholder information, or face significant penalties. What is important for Michigan residents with offshore accounts is to make certain they report this information as well. …

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transition tax on foreign earnings

Confusion Regarding Transition Tax on Foreign Earnings

Under 26 U.S. Code § 965, shareholders throughout the U.S. must pay a transition tax on foreign earnings from specific foreign corporations. The IRS deems this tax as a repatriation of the income. Lawmakers entitled 26 U.S. Code § 965 as: “Treatment of deferred foreign income upon transition to participation exemption system of taxation.” Unfortunately, the content …

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offshore reporting

Offshore Reporting Deadline Quickly Approaching

Tax attorneys understand how serious the penalties are concerning nondisclosure of offshore assets. For purported violations, the IRS may seize 50 percent of the account’s value, file possible criminal charges, and assess other penalties. The IRS is giving notice that taxpayers working outside of the country must file their federal income tax returns by June 15. This …

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offshore tax enforcement

Changes in Offshore Tax Enforcement May Be Coming Soon

On behalf of Silver Tax Group posted in Offshore Accounts on Wednesday, May 2, 2018. There have been voluntary disclosure programs in place to entice taxpayers to come clean about unreported foreign assets since 2009. These programs allow for promises of decreased penalties. They may also allow for avoidance of prosecution in return for participation. But due to decreased …

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a close to the OVDP and offshore reporting

OVDP Program Regarding Offshore Reporting to Close

On behalf of Silver Tax Group posted in Offshore Accounts on Thursday, March 22, 2018. The IRS plans on bringing to a close the Offshore Voluntary Disclosure Program (OVDP) put in place in 2014. The plan is to close this program by September 28. However, this announcement made by the IRS at least allows for Michigan taxpayers time to still take …

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The Impact of the Tax Cuts and Jobs Act

Offshore Income and the New Tax Act

On behalf of Silver Tax Group posted in Offshore Accounts on Tuesday, February 27, 2018. The Tax Cuts and Jobs Act will impact all taxpayers including those residing offshore. The act’s provisions include adjustments to corporate rates and exclusion rates. With changes to the tax code, authorities promise simplification. But that does not mean offshore residents will see tax …

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amnesty programs expanding

Voluntary Disclosure Programs and Offshore Assets

On behalf of Silver Tax Group posted in Offshore Accounts on Monday, February 5, 2018. The IRS may be expanding amnesty programs for taxpayers facing penalties due to reporting issues regarding their offshore accounts. This possibly is because the IRS views such programs as a success. The aim is to recover even more money owed. The aggressive efforts by …

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limited power of IRS

The IRS and Statutes of Limitation

On behalf of Silver Tax Group posted in Offshore Accounts on Monday, January 22, 2018. Courts continue hearing cases concerning filings of the Report of Foreign Bank and Financial Account (FBAR). There are significant penalties that accompany the failure to file an FBAR. This can include significant fines and even prison time. The IRS does not have unlimited powers, …

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FATCA and underreporting of income

FATCA and Underreporting of Income

The Foreign Account Tax Compliance Act (FATCA) governs reporting of foreign financial institutions concerning assets held by American citizens. Such institutions face substantial penalties for failing to report these assets. “Combat tax evasion” U.S. tax officials deal with this underreporting through FATCA. In 2010, President Obama stated the primary purpose of FATCA was to “combat …

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taxes of bitcoins and offshore accounts

Bitcoins and Offshore Reporting Requirements

On behalf of Silver Tax Group posted in Offshore Accounts on Wednesday, November 29, 2017. Federal officials closely scrutinize reporting of cryptocurrency gains on tax returns. This is in large part due to difficulties determining whether cryptocurrency is property or currency. Classifying bitcoins and cryptocurrency as property or currency has tax implications. In a foreign country, a U.S. citizen may not …

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new tax reform proposals

What’s Included in the New Tax Reform Proposals?

On behalf of Silver Tax Group posted in Offshore Accounts on Wednesday, October 25, 2017. Every presidential administration promises some sort of significant tax reform. While the promise is almost always that the impact will be beneficial to the ordinary taxpayer, issues and unintended consequences usually arise. Michigan residents will nevertheless wish to pay attention to new changes in …

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FATCA requirements

Will You Have to Abide by FATCA Requirements?

On behalf of Silver Tax Group posted in Offshore Accounts on Friday, October 20, 2017. If you as a Michigan resident have foreign assets in excess of $10,000, please make certain you are in compliance with federal tax laws. The rules are complex, and noncompliance comes with penalties including seizure of assets and criminal charges. Under the Foreign Account Tax …

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FATCA requirements

FATCA Requirements and Foreign Insurers

On behalf of Silver Tax Group posted in Offshore Accounts on Monday, September 18, 2017. Passed in 2010, the Foreign Accounts Tax Compliance Act (FATCA) continues to be controversial. FATCA requires specific foreign financial institutions to report on assets belonging to American citizens. Reporting under FATCA is complicated. And the consequences for noncompliance with FATCA are severe. FATCA requirements …

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tax breaks and job seekers

FATCA Challenge May Move to the Supreme Court

On behalf of Silver Tax Group posted in Offshore Accounts on Thursday, September 7, 2017. Congress passed the Foreign Account Tax Compliance Act (FATCA) with the idea of collecting more tax revenues from U.S. citizens living outside of the country. By implementing a series of complex reporting requirements on foreign financial institutions, authorities were hoping to identify accounts and …

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risky procedure for foreign accounts

The Risky Streamlined Filing Procedure for Foreign Accounts

When you as a Michigan resident have combined balances of foreign accounts exceed $10,000, you will need to file a disclosure statement with tax authorities. Failure to do so could result in tax evasion charges, and this can bring with it criminal penalties. However, in 2009 the IRS began offering opportunities to disclose this unreported …

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willfulness and the disclosure of foreign account

Willfulness and the Disclosure of Foreign Account Info

On behalf of Silver Tax Group posted in Offshore Accounts on Tuesday, July 11, 2017. We’ve spoken many times on this blog about the complex reporting requirements that accompany ownership of foreign accounts. Beyond the complexity, it is extremely difficult for individual taxpayers to keep track of all of the rules pertaining to these accounts. Disclosure of foreign account …

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passive income and reporting

Passive Income and The Strict Reporting Requirements

On behalf of Silver Tax Group posted in Offshore Accounts on Tuesday, May 30, 2017. While the taxes you pay concerning foreign investments may not always be large, the failure to comply with rules pertaining to reporting of this income can result in severe consequences. The rules for reporting such income are also highly complex. Understand the requirements Most …

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exclusion of certain foreign income

Exclusion of Certain Foreign Income from Your Tax Forms

On behalf of Silver Tax Group posted in Offshore Accounts on Wednesday, May 10, 2017. We have often spoken about the difficulties taxpayers face concerning compliance with offshore income reporting requirements. This includes significant enforcement of regulations contained under the Foreign Account Tax Compliance Act (FATCA). The reporting requirements under FATCA are stringent. Not report certain foreign income Sometimes, …

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Legislators looking at repeal of FATCA

Legislators Looking at Repeal of FATCA

On behalf of Silver Tax Group posted in Offshore Accounts on Wednesday, April 19, 2017. With every new presidential administration, there are likely to be changes in federal tax policy. Some of these changes can radically impact the way that Michigan taxpayers will file their taxes and report on earnings. One such possible measure involves repeal of the Foreign …

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IRS disclosure programs

Offshore Income and IRS Disclosure Programs

On behalf of Silver Tax Group posted in Offshore Accounts on Thursday, March 30, 2017. The Internal Revenue Service will likely continue to crackdown on alleged failures to report offshore income and foreign assets. Any taxpayer with over $10,000 invested in foreign bank accounts could be a target for the IRS. Tax penalties for noncompliance are significant. Not only can …

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offshore accounts and John Doe summons

Offshore Accounts and the Use of John Doe Summons

On behalf of Silver Tax Group posted in Offshore Accounts on Thursday, February 23, 2017. A recent federal court decision demonstrates the determination of the IRS in tracking down offshore revenue. The federal court authorized the agency to use a John Doe summons in order to locate information about American citizens holding offshore accounts in Panama. Specifically, the IRS desired to use …

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Deferred compensation plans and offshore accounts

Deferred Compensation Plans and Offshore Accounts

On behalf of Silver Tax Group posted in Offshore Accounts on Thursday, January 12, 2017. Many U.S. citizens, including Michigan residents, put their offshore savings into deferred compensation plans. Taxpayers may do this in an attempt to defer otherwise taxable income to avoid paying at current tax rates. In fact, many individuals with offshore accounts have been doing this since the …

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tax inversions

Tax Inversions and Intercompany Debt

On behalf of Silver Tax Group posted in Offshore Accounts on Wednesday, November 16, 2016. The U.S. Treasury has long tried to prevent inversions and cross-border avoidance maneuvers. A tax inversion occurs when an American corporation relocates to a nation with lower tax rates while continuing extensive operations in our country. Certain rules concern corporations merging with smaller foreign …

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offshore revenue

Significant Targeting of Offshore Revenue by the IRS

On behalf of Silver Tax Group posted in Offshore Accounts on Thursday, November 3, 2016. Recent actions document IRS efforts to target offshore revenues. It appears that offshore voluntary compliance efforts now exceed more than $9.9 billion in collected taxes, penalties and interest since 2009. An IRS announcement states that their efforts have brought close to 100,000 taxpayers into compliance regarding offshore …

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planning offshore tax

More Rules to Tax Offshore Business in the Planning Stage

We can expect more crackdowns by federal regulators concerning taxing of U.S. companies doing business overseas. The U.S. Treasury recently proposed a series of regulations. The intent of such rules is to make it more difficult for companies to reduce the amount of taxes owed by the practice of shifting profits to foreign companies. The White House Office …

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offshore account information by IRS

IRS Continues Efforts to Locate Offshore Account Information

You can plan on the Internal Revenue Service continuing in its efforts to locate offshore account information. As an example, Switzerland recently announced its plan for disclosure of account information from HSBC Holdings to the IRS. HSBC is a private Swiss bank. The Swiss announcement was to alert HSBC account holders of the plans to release this information. …

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disclose foreign assets

Failed to Disclose Foreign Assets? There Are Good Options to Fix That.

Those with assets in foreign bank accounts of over $10,000 are required to file the proper documentation with the IRS, including a Report of Foreign Bank and Financial Accounts(FBAR). Failure to do so leads to numerous penalties. Even the most business-savvy individuals can instantly find themselves facing unexpected issues related to compliance with the Foreign Account Tax Compliance …

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FATCA disclosure

FATCA Disclosure Could still Mean Prosecution for Some Taxpayers

Tens of thousands of Americans with offshore bank accounts could now potentially be facing prosecution under the Foreign Account Tax Compliance Act (FATCA). More than 30,000 taxpayers have, since 2012, disclosed foreign accounts under a streamlined IRS program which offered a grace period against additional penalties in exchange for future compliance with offshore account reporting …

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taxes penalties for entrepreneur

Entrepreneur ordered to pay $1.1 billion in taxes/penalties

This week was the deadline for filing FBAR disclosures on foreign accounts. Fittingly, a Texas federal judge also ordered an entrepreneur, of the arts-and-crafts chain Michael’s, to pay significant taxes and penalties for schemes that utilized offshore tax havens. A breakdown reported by the Wall Street Journal shows the severe impact of penalties. The back tax bill was …

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IRS and personal social security

Questions to Answer Before a First Foreign Account Filing

Do you have foreign accounts as part of investment strategy? Have parents in another country given you signature authority over their bank accounts? Did you inherit a trust that contains assets located at a foreign bank? If your offshore assets totaled $10,000 or more at any point during 2015, you should file an FBAR – Report of …

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