Whether they be a dual-citizen, legal permanent resident, etc., it is important for those persons that have attained status as a United States (U.S.) taxpayer to have a legal analysis completed under federal income tax law before either formally (mark-to-market expatriation) or informally renouncing citizenship.

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.

Persons with undisclosed foreign accounts should be aware of the whistleblower program and corresponding awards. If a taxpayer worked with a facilitator or representative in a foreign jurisdiction, that individual may choose to open a whistleblower case if they know the facts and circumstances of another taxpayer’s case with regard to failure to report foreign financial accounts.

“As part of its agreement with DOJ, Bank Leumi must provide the names of more than 1,500 of its U.S. account holders.”