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Los Angeles Tax Law Blog

IRS 80- Swiss Banks 0

The formal IRS/Department of Justice (DOJ) Swiss Bank Program has concluded with 80 Swiss banks coming forward. The banks agreed to provide information about personnel, depositors and advisors who were participated in or assisted U.S. taxpayers in offshore tax evasion. In addition to disclosure and cooperation with investigations each of the banks paid substantial penalties. In exchange for the disclosures, cooperation and penalties, the banks received Non-prosecution agreements. But let there be no mistake, the offshore tax program is far from over. There is substantial political pressure on the IRS and DOJ and exemplified by the recent statement of Senator John McCain.

Caution: Not All Iran Sanctions Were Terminated

U.S. persons, including pemanent resident aliens and dual nationals should note that the Lifting of U.S. Sanctions on Itran under the  Joint Comprehensive Plan of Action does not lift all sanctions.  The following is a link to acomprehensive set of Freqnently Asked Questions (FAQ's): https://www.treasury.gov/resource-center/sanctions/Programs/Documents/jcpoa_faqs.pdf

Who Must Report Foreign Corporations

The IRS recently published published an internal guideance on who must report interests in foreign corporations and the penalties for non-compliance. The timing of the guideance is important as the first "information exchange" and "information reporting" under the Foreign Account Tax Compliance Act, "FATCA" occurred September 30,2015.  The IRS and Justice Deptartment will now be able to cross check the data provided through the infomation exchanges with filed returns and initiate civil examans and in some cases criminal investigations against non-filers.  It is no longer a matter of if non-filers will be discovered, but when.   

Giving Up U.S. Citizenship - Estate and Gift Tax Traps

It may be a commone misunderstanding that a U.S. citizen or permanent resident (Green Card holder) can give up their citizenship or surrender their Green Card and  then as a non-U.S. taxpayer make gifts or pass their estate to U.S. taxpayers free of estate and gift tax.  The IRS recognized this loophole and has proposed a new Regulation designed to  tax the recipient of the gifts or inheritances from "covered expatriates" at maximum estate and gift tax rates. 

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