Tag Archives: foreign account

Bank Leumi Admits to Assisting U.S. Taxpayers in Hiding Assets in Offshore Bank Accounts

December 30, 2014  |   Posted by :   |   Tax Evasion,Unreported Income   |   0 Comments

Department of Justice, Office of Public Affairs, 12/22/14 A major Israeli international bank admitted that it conspired to aid and assist U.S. taxpayers to prepare and present false tax returns to the Internal Revenue Service (IRS) by hiding income and assets in offshore bank accounts in Israel and elsewhere around the world.  A deferred prosecution […]

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Tax shelter shake-up hits home

October 22, 2014  |   Posted by :   |   Tax Evasion,Unreported Income   |   0 Comments

A federal crackdown and a new act make life tougher for lawyers and accountants. By David Koeppel, Crain’s New York Criminal tax attorney Robert Fink views the conviction and sentencing of his client Dr. Michael Canale – on tax fraud charges in New York state federal court in 2012 – as representative of everything that’s […]

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Offshore Tax Crackdown Opens With 30% Penalties for Banks

July 02, 2014  |   Posted by :   |   Tax Evasion,Unreported Income   |   0 Comments

By Richard Rubin, Bloomberg.com The Internal Revenue Service is about to get an unprecedented look at bank accounts and investments U.S. citizens hold abroad, through a law that is making it harder to hide assets from the tax collector. Tomorrow, the U.S. government will start imposing 30 percent taxes on many overseas payments to financial […]

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FATCA – Pre-Immigration Planning

April 16, 2013  |   Posted by :   |   FATCA/FBAR   |   0 Comments

Under the Foreign Account Tax Compliance Act (“FATCA”), effective 1/1/14, Foreign Financial Institutions (“FFI”) must withhold 30% tax on U.S. source “withholdable payments” (and “pass-through payments’) including: 1. U.S. Source FDAP Income: including portfolio interest; 2. Gross proceeds from U.S. securities. To avoid the withholding tax the foreign financial institution either has an agreement with […]

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Qualified Intermediary – QI General

February 26, 2013  |   Posted by :   |   Qualified Intermediary   |   0 Comments

A QI is any foreign intermediary (or foreign branch of a U.S. intermediary) that has entered into a qualified withholding agreement with the IRS. A QI is a payee (of U.S. source income) to the extent the QI assumes primary withholding responsibility as primary Form 1099 reporting and backup withholding responsibility for a payment, in […]

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FATCA Update – Overseas Accounts

February 25, 2013  |   Posted by :   |   FATCA/FBAR   |   0 Comments

On 1/17/13, the U.S. Treasury Department published new U.S. information- reporting rules on overseas accounts to catch Americans who dodge U.S. taxes by secreting their assets offshore. Targeting foreign banks, the Foreign Account Tax Compliance Act (“FATCA”) rules, published 1/17/13 by the U.S. Treasury, require foreign financial institutions with $50,000 of any American taxpayer’s assets […]

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FBAR – Foreign Accounts with Multiple Signatories

January 23, 2013  |   Posted by :   |   FATCA/FBAR   |   0 Comments

*On 6/24/09, the IRS updated their Voluntary Disclosure FAQ clarifying the FBAR reporting requirements for foreign accounts with multiple signatories: If parents have a jointly owned foreign account on which they have made their children signatories, the children have an FBAR filing requirement but no income. Should the children just file delinquent FBARs as described […]

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FBAR – Offshore Hedge Funds

January 22, 2013  |   Posted by :   |   FATCA/FBAR   |   0 Comments

*Published in The California Tax Lawyer (Summer 2009 Edition). FBARs and Offshore Hedge Funds After the landmark agreement between the U.S. and Swiss government over secret UBS Swiss bank accounts held by U.S. citizens, the IRS is now focusing on hedge funds in the Cayman Islands. Recently, IRS officials advised that certain U.S. investors in […]

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FATCA – Foreign Financial Institutions – Qualified Intermediary

January 04, 2013  |   Posted by :   |   FATCA/FBAR   |   0 Comments

Under the 2010 HIRE Act (IRC §1471(c)(1)), a foreign financial institution that is a party to a qualified intermediary agreement with the IRS must report the following information regarding each U.S. account maintained by the institution: 1) The name, address, and TIN of each account holder that is a specified U.S. Person; 2) The name, address and […]

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FATCA – Withholding Agents

December 28, 2012  |   Posted by :   |   FATCA/FBAR   |   0 Comments

The Foreign Account Tax Compliance Act (The “Act”) expands withholding rules and additional reporting requirements for foreign financial institutions and non-financial foreign entities. Under U.S. tax law, a withholding agent must deduct or withhold a tax equal to 30% on any withholdable payment (e.g., interest, dividends, rents, salaries, wages, premiums, annuities, compensations, and other fixed […]

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