Similar to the model rules of ethics or the uniform rules of evidence, probate or the commercial code, a uniform code of foreign income state taxation would make the analysis for state tax planning consistent and transparent.
The 100 Swiss Category 2 banks that signed up for the Department of Justice non-prosecution agreement (NPA) deal last December (2013) have just received the details of what is needed to comply.
A New Hampshire man pleaded guilty yesterday in the U.S. District Court for failing to report approximately $170,000 in income earned from offshore bank accounts from 2006-2009.
With the IRS crackdown on offshore accounts in full swing, all tricks that were once used by banks for offshore tax evasion are no longer effective. The tactics below were presented to the U.S. Senate Permanent Subcommittee on Investigations, documenting the most common tax haven bank secrecy tricks.
The Israeli Finance Ministry announced on Monday, October 27, 2014 that Israel will be joining the international mechanism for the sharing of information on financial accounts. While the automatic exchange of information for tax purposes will not be fully in effect until the end of 2018, it is a very strong signal from Israel that the country is taking proactive steps to fight tax evasion.
Even under international pressures in conjunction with pressures from the EU and the OECD, Luxembourg has recreated itself as the wealth management center of Europe. Banks from China, Switzerland and the Islamic states are committed to maintaining large banking hubs in Luxembourg due the countries “tax friendliness.”
The Hawkins case provides an analogy for the definition of willfulness that could be applied for offshore voluntary disclosure and streamline filing cases. In the Hawkins case the Ninth Circuit Court of Appeals reviewed an appeal from the Northern District of California.
Five Stone is attending the 62nd Annual Taxation Conference held yesterday, December 3, 2014 and today, December 4, 2014. Yesterday included a great lecture from Nina Olsen, the National Taxpayer Advocate and the voice of the taxpayer before the IRS and Congress.
When interviewing a taxpayer that has offshore compliance issues with the Internal Revenue Service, practitioners (Attorneys, CPAs, Enrolled Agents) take a myriad of approaches to develop the case to be able to provide a recommendation for compliance.
As we are heading into the holidays and the New Year, I have received several questions from current clients, prospective clients and other practitioners regarding the disclosure period for Offshore Voluntary Disclosure Program and Streamline filing compliance procedure.