December 10, 2018

IRS Examination Coverage

The Internal Revenue Service has listed the percentage of tax returns filed and examined by the amount of Adjusted Gross Income, see below. The returns showing Adjusted Gross Income, AGI, for 2016 of $10,000,000 or more were the highest audit at 14.52%. The returns with AGI of $75,000 to under … [Read more...]

Foreign Bank Account Report due June 30, 2016

This alert serves as a reminder that you may need to file a Report of Foreign Bank and Financial Accounts with respect to your foreign assets. For calendar year 2015, an FBAR is required to be filed on or before June 30, 2016. The FBAR form is now called FinCen Report 114, and superseded the Form TD … [Read more...]

End of the year gifting

Hello to you as this Holiday Season is now upon us with such energy and joy of families being together after a long year. I wish you a safe and happy Holiday and a great New Year. As a tax attorney, I just can't stop thinking of last minute tips that may help you and me for April's filings. … [Read more...]

Is there a DING knocking at your client’s door?

  In 2013 the Internal Revenue Service (“Service”) issued several private letter rulings (“PLRs”) sanctioning the use of a state income tax planning strategy known as the Delaware Incomplete Non-Grantor trust—or the “DING” trust. DING trusts are designed to lower the state income tax burden … [Read more...]

DOJ Offers Swiss Banks a Deal

In 2013, The Justice Department (DOJ) announced a program that is designed to encourage Swiss banks to cooperate in their ongoing investigations of the use of foreign bank accounts to commit tax evasion. DOJ also released a joint statement with the Swiss Federal Department of Finance, stating that … [Read more...]

IRS Starts Scrutinizing the Insurance Industry with Swiss Partners

In accordance with the DOJ Swiss Banking deal, Swisspartners, a group of Swiss asset management and life insurance companies (which, among its other insurance products, provided customized private placement life insurance polices to US persons) agreed to resolve a US criminal tax investigation. … [Read more...]

Credi Suisse Latest in Agreeing to Turn Over Information

Credit Suisse resolved its IRS investigation regarding certain banking practices that occurred with respect to U.S. taxpayers. The Credit Suisse resolution follows the IRS resolution with UBS and closure of Wegelin & Co., Switzerland’s oldest private bank, after its U.S. criminal … [Read more...]

FATCA’S New International Disclosure and a 30% Investment Income Tax Arrived July 1st

In 2010, Congress and President Obama carried into law the Hiring Incentives to Restore Employment Act (“HIRE Act”). The HIRE Act contained a set of provisions named the Foreign Account Tax Compliance Act (“FATCA”), which the U.S. Treasury stated “targets the illicit activities of some wealthy … [Read more...]

IRS Voluntary Disclosure Program is Significantly Revised

The IRS initiated a new voluntary disclosure program for US taxpayers with foreign accounts on June 18, 2014. The IRS also noted some interesting statistics regarding its previous two foreign account voluntary disclosure programs as well as its audit programs. Among the more notable statistics, the … [Read more...]

New Changes to OVDP and Streamlined Procedure

Expanded streamlined procedures are now available to a wider population of U.S. taxpayers living outside the country and, for the first time, to certain U.S. taxpayers residing in the U.S. The expanded streamlined procedures are intended for U.S. taxpayers whose failure to disclose their offshore … [Read more...]