IRS launches video campaign to help international taxpayers.
For taxpayers seeking relief under Streamline Filing 
Compliance Procedures, recent IRS changes provide some welcome news. The new guidance puts additional burdens on the examiners for Fbar penalties and the determination of willfulness vs. non-willfulness.
Important to note though is that taxpayers need to be wary of issuing blanket statements when determining willfulness. There needs to be a thorough analysis of each year for the failure to file Fbar reports as well as a separate analysis (under a different legal standard than Fbar) for failure to report foreign income.
IRS Offers Videos for Taxpayers
Realizing that expat taxpayers face considerable hurdles in complying with Fatca, the IRS has launched three new videos on its YouTube channel to address the following concerns:
- International Taxpayers: Filing Requirements
- International Taxpayers: Foreign Earned Income Exclusion
- International Taxpayers: Individual Taxpayer Identification Number (ITIN)
The IRS has promised to release several more videos in the coming weeks to help international tax filers navigate requirements.
Two More Swiss Banks Settle with the DOJ
The Department of Justice came to resolutions with Rothschild Bank AG and Banca Credinvest SA under the Program for Swiss Banks. This now expands the Ovdp Faq 7.2 named bank or facilitator list to twenty-one. Any taxpayer with undisclosed foreign financial accounts in one of the aforementioned banks just saw their Ovdp Title 26 Misc. Uniform Penalty jump from 27.5% to 50% overnight.
Here are the broad items to take away:
- Banca Credinvest SA – Penalty of $3,022,000
- Rothschild Bank AG – Penalty of $11,015,000
The above banks must provide full disclosure of all US names and values associated with accounts from August 1st, 2008, to the present. They must close all recalcitrant accounts within two years and the dormant accounts within four.
The above banks must provide full disclosure of all US names and values associated with accounts from August 1st, 2008, to the present. They must close all recalcitrant accounts within two years and the dormant accounts within four.
Rothschild a Little Corked
The banking arm of Rothschild has also been shown to have questionable secrecy practices using shell companies and banking secrecy to conceal undeclared assets that some were hiding behind sham entities in Liechtenstein, Panama and the British Virgin Islands. Let’s hope Mr. Rothschild can return this arm of the family empire to the same glory and excellence as the unparalleled Château Lafite-Rothschild and rid it of its corked assets.
About Five Stone Tax Advisers
Five Stone Tax Advisers has years of experience negotiating directly with the IRS to get the best possible outcome for you. Our International Tax Advisory and Compliance unit has a team of tax attorneys, certified public accountants and enrolled agents that form a single sourced point of contact that will provide services for all the legal, compliance and financial reconstruction aspects of offshore account cases.
