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• Foreign Banks Subject to U.S. Law

  The U.S. Department of Justice (DOJ) has made it clear that it will continue an aggressive practice of prosecuting foreign banks and bank personnel that have materially aided U.S. taxpayers in hiding money offshore. The most current examples are the Swiss banks Weglin & Co and Julius Baer. The DOJ is undeterred in its prosecutions [...]

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• Domestic Voluntary Disclosures, Why?

  Since 2009 there have been three offshore voluntary disclosure programs offered by the IRS. The major difference among the three programs is the FBAR penalty, known as the civil miscellaneous penalty. The penalty has graduated between the three programs 2009, 2011 and 2012 from 20% to 27.5% of the highest single year financial account balnace [...]

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• Voluntary Disclosure versu Prosecution

  For taxpayer’s who had direct or indirect control over offshore financial accounts which aggregated $10,000 or more in calendar year 2012 a Report of Foreign Bank or Financial Account, known as an FBAR (Form TD 90-F. 22.1) is due and must be received by the IRS at the Detroit Center by June 30, 2013. Since [...]

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• International Tax Planning for Businesses is Art and Politics

  The recent Congressional hearings on taxation of multinational corporations drew a lot of focus on the low tax rates and low taxes paid (relative to revenue). Congress expressed outrage that the largest companies in the world pay modest rates of tax. The outrage is quizical. The Congress has the power to change the rules if [...]

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