foreign bank account: Streamlined Compliance for Non-Resident U.S. Taxpayers, Part IV
- 01/17/14 09:05 PM
The focus of our practice is civil and criminal taxpayer representation, as well as assisting taxpayers with foreign bank account issues, and we see many taxpayers in Stamford, Connecticut who are dealing with reporting foreign bank accounts and their failure to file United States Tax returns while living abroad. Part I of this series discussed the new streamlined compliance procedures for U.S. taxpayers living abroad have failed to timely file U.S. federal income tax returns or Reports of Foreign Bank Account Reports (FBARs), Form TD F 90-22.1, but have recently become aware of their filing obligations and now seek to come … (0 comments)
foreign bank account: Streamlined Compliance for Non-Resident U.S. Taxpayers, Part III
- 01/17/14 08:55 PM
The focus of our practice is civil and criminal taxpayer representation, as well as assisting taxpayers with foreign bank account issues, and we see many taxpayers in Stamford, Connecticut who are dealing with reporting foreign bank accounts and their failure to file United States Tax returns while living abroad. Part I of this series discussed the new streamlined compliance procedures for U.S. taxpayers living abroad have failed to timely file U.S. federal income tax returns or Reports of Foreign Bank Account Reports (FBARs), Form TD F 90-22.1, but have recently become aware of their filing obligations and now seek to … (0 comments)
foreign bank account: Streamlined Compliance for Non-Resident U.S. Taxpayers, Part II
- 01/17/14 08:44 PM
The focus of our practice is civil and criminal taxpayer representation, as well as assisting taxpayers with foreign bank account issues, and we see many taxpayers in Stamford, Connecticut who are dealing with reporting foreign bank accounts and their failure to file United States Tax returns while living abroad. Part I of this series discussed the new streamlined compliance procedures for U.S. taxpayers living abroad have failed to timely file U.S. federal income tax returns or Reports of Foreign Bank Account Reports (FBARs), Form TD F 90-22.1, but have recently become aware of their filing obligations and now seek to come … (1 comments)
foreign bank account: Streamlined Compliancefor Non-Resident U.S. Taxpayers, Part I
- 01/17/14 08:35 PM
The focus of our practice is civil and criminal taxpayer representation, as well as assisting taxpayers with foreign bank account issues, and we see many taxpayers in Stamford, Connecticut who are dealing with reporting foreign bank accounts and their failure to file United States Tax returns while living abroad. These new streamlined filing compliance procedures for non-resident U.S. taxpayers are being implemented in recognition that some U.S. taxpayers living abroad have failed to timely file U.S. federal income tax returns or Reports of Foreign Bank Account Reports (FBARs), Form TD F 90-22.1, but have recently become aware of their filing … (1 comments)
foreign bank account: IRS Foreign Account (FATCA) Implementation between US and Italy
- 01/15/14 02:11 AM
The focus of our practice is civil and criminal taxpayer representation,as well as assisting taxpayers with foreign bank account issues, and we see many taxpayers in Greenwich, Connecticut who are dealing with reporting foreign bank accounts and dealing with related issues. It was just announced that The United States has signed an intergovernmental agreement (IGA) with Italy to implement the Foreign Account Compliance Act (FATCA). The two countries have had a long-standing and close relationship with respect to mutual assistance in tax matters and they entered into the agreement to improve international tax compliance by further building on that relationship. FATCA … (0 comments)
foreign bank account: US & Switzerland Joint Statement Regarding Tax Evasion Investigations
- 12/23/13 05:42 AM
The focus of our practice is civil and criminal taxpayer representation, and we have represented many taxpayer's involved with foreign bank accounts in Greenwich, Connecticut and New York, New York. The increased focus on international tax enforcement by both the IRS and the Department of Justice comes as no surprise. However, the speed at which the United States Government has been able to improve its relationship and obtain information regarding foreign bank accounts held by US taxpayers from foreign governments has been most impressive. The Department of Justice recently announced a program that will encourage Swiss banks to cooperate in … (0 comments)
foreign bank account: IRS Stamford CT: IRS Releases Guidance on Foreign Financial Asset Reporting
- 12/15/11 07:56 AM
We frequently get involved in helping taxpayers sort out their foreign bank account issues with the IRS in Stamford, CT and elsewhere. The Internal Revenue Service in coming days will release a new information reporting form that taxpayers will use starting this coming tax filing season to report specified foreign financial assets for tax year 2011. Form 8938 (Statement of Specified Foreign Financial Assets) will be filed by taxpayers with specific types and amounts of foreign financial assets or foreign accounts. It is important for taxpayers to determine whether they are subject to this new requirement because the law imposes significant penalties … (0 comments)
foreign bank account: Stamford CT IRS Criminal Tax: Venue for Failure to File FBAR Lies in Any District that Houses an IRS Office
- 12/07/11 12:59 PM
We represent taxpayers in IRS Criminal tax investigations frequently, and often deal with foreign bank account issues in Stamford, Connecticut as well as elsewhere in New England. In United States v. Bradley, 644 F.3d 1213 (11th Cir. 2011), the Eleventh Circuit held, inter alia, that venue for failure to file an FBAR properly lies in any district that houses a local IRS office, so long as the chosen venue does not create a constitutional hardship for the defendant. As discussed above, the Bradleys and their company, Bio–Med Plus, Inc., engaged in multiple schemes to defraud the Florida and California Medicaid programs … (0 comments)
foreign bank account: Stamford CT IRS Criminal Tax: Fifth Amendment Privilege Held to be Inapplicable to Subpoena for Foreign Bank Records Required under Bank Secrecy Act
- 12/07/11 12:50 PM
We represent taxpayers in IRS Criminal tax investigations frequently, and often deal with foreign bank account issues in Stamford, Connecticut as well as elsewhere in New England. In In re Grand Jury Investigation M.H. v. United States, 648 F.3d 1067 (9thCir.2011), the Ninth Circuit held that foreign bank account records required to be kept under the Bank Secrecy Act (“BSA”) fall within the Required Records Doctrine, thus rendering the Fifth Amendment privilege against self-incrimination inapplicable to a subpoena for these records. When I am asked by clients about records demanded by the government, I often have to explain that records required … (0 comments)
foreign bank account: IRS Foreign Bank Accounts Stamford, Connecticut: The IRS continues its assault on hidden foreign bank accounts with its relentless prosecutions.
- 10/26/11 03:40 PM
We frequently represent clients who have hidden bank accounts in foreign countries and would like to come forward and clean up their issue and sleep better at night. Prior to 2009 we did through a voluntary disclosure with the IRS criminal division. Since 2009 there have been two voluntary disclosure initiatives (the 2011 one ends August 31st). If sleeping better at night and reduced penalties with reduced risk of criminal prosecution was not enough of an inducement, the recent headlines should be. Reading the IRS announcements that have been streaming out of its criminal investigations division makes for interesting reading. The … (0 comments)
foreign bank account: IRS Tax Evasion Hartford, CT: IRS Shows Continued Progress on International Tax Evasion
- 09/15/11 01:37 PM
We represent many taxpayers involved in criminal tax situations, including voluntary disclosure of foreign bank accounts. Today the IRS released a notice that it continues to make strong progress in combating international tax evasion, with new details announced today showing the recently completed offshore voluntary disclosure initiative (OVDI) program pushed the total number of voluntary disclosures up to 30,000 since 2009. In all, 12,000 new applications came in from the 2011 offshore program that closed last week. The IRS also announced today it has collected $2.2 billion so far from people who participated in the 2009 program, reflecting closures of about … (0 comments)
foreign bank account: FBAR Prosecution Hartford CT: US department of Justice Announces HSBC India Client Indicted for Filing False Tax Returns and Failing to Report Foreign Bank Account
- 07/09/11 02:39 AM
Our firm represents a significant number of taxpayers in Hartford, Connecticut and elsewhere who have foreign bank accounts and would like to come forward and resolve the matter with the IRS and/or Department of Justice. I cannot stress the importance of coming forward prior to the August 31st deadline, as the current stream of prosecutions coming out now do not bode well for those folks holding out. The Department of Justice just released its latest announcement of a prosecution coming from HSBC in India. Dr. Arvind Ahuja of Greendale, Wis., was indicted today by a federal grand jury in Milwaukee on … (1 comments)
foreign bank account: IRS Foreign Bank Account Hartford, Connecticut:IRS ANNOUNCES NEW 2011 VOLUNTARY DISCLOSURE PROGRAM FOR OFFSHORE BANK ACCOUNTS
- 02/09/11 01:30 AM
<!--StartFragment--> We frequently represent taxpayers in criminal tax situations. The Internal Revenue Service announced today a special voluntary disclosure initiative designed to bring offshore money back into the U.S. tax system and help people with undisclosed income from hidden offshore accounts get current with their taxes. The new voluntary disclosure initiative will be available through Aug. 31, 2011. “As we continue to amass more information and pursue more people internationally, the risk to individuals hiding assets offshore is increasing,” said IRS Commissioner Doug Shulman. “This new effort gives those hiding money in foreign accounts a tough, fair way to resolve their tax problems … (0 comments)
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The focus of our practice is civil and criminal taxpayer representation, as well as assisting taxpayers with foreign bank account issues, and we see many taxpayers in Stamford, Connecticut who are dealing with reporting foreign bank accounts and their failure to file United States Tax returns while living abroad. 
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