The Foreign Account Tax Compliance Act (FATCA) was enacted by Congress in 2010 as a way to target non-compliance by U.S. taxpayers using foreign accounts. Here are some statistics and numbers related to FATCA’s implementation.
I am pleased to announce that Internal Revenue Service veterans, Jeremiah O’Sullivan and Paul Reska have joined the McMahon Law Office. As the government continues to focus on revenue collection, I have seen a sharp increase in the demand for experienced professionals capable of handling difficult tax disputes. Jeremiah and Paul’s in-depth knowledge of the IRS audit and appeals processes allows me to grow the firm and assist more taxpayers.
In June, the IRS announced new procedures to help U.S. citizens residing overseas, including dual citizens, catch up with tax filing obligations and assist with resolving some issues related to certain foreign retirement plans. While the new procedures become effective September 1, 2012, the IRS has yet to issue more details or specific factors used to determine compliance risk.
The Treasury Department and the Internal Revenue Service (IRS) have issued proposed regulations for the next major phase of implementing the Foreign Account Tax Compliance Act (FATCA). Additionally, the United States, France, Germany, Italy, Spain and Britain issued a joint statement saying they wanted “to intensify their cooperation in combating international tax evasion.” The U.S. agreed to “reciprocate in collecting and exchanging” information about U.S. accounts held by residents of those countries.
The Internal Revenue Service has persuaded U.S. taxpayers to disclose hidden offshore bank accounts but then sometimes failed to cap the penalties, as promised, an agency watchdog said on Wednesday, accusing the IRS of “bait and switch.”
According to the SonntagsZeitung and World Radio Switzerland 11 Swiss banks have until Tuesday, December 20, 2011 to agree to deliver detailed information about their U.S. offshore banking businesses in order to avoid legal action.
For the second time in the past two years, a Swiss bank has handed over client records to the IRS. Rupert Neate reports in the Guardian that Credit Suisse, the second largest bank in Switzerland, has produced details on 130 Americans suspected of evading billions of dollars in taxes.
The 2011 Offshore Voluntary Disclosure Initiative (“OVDI”) is different in several ways from the 2009 Offshore Voluntary Disclosure Program (“OVDP”). The deadline to apply to the OVDI is August 31, 2011. Similar to the 2009 OVDP, the 2011 OVDI is intended to encourage taxpayers with unreported offshore accounts to come forward voluntarily with the primary benefits of (a) no criminal referral; and (b) a reduced penalty.
The IRS spokesman Frank Kieth recently said that the IRS would soon announced a second Offshore Voluntary Compliance Program for taxpayers who have unreported foreign bank accounts. Details of the new program should be released soon and we will post an update on this program as soon as details are disclosed.
McMahon & Associates, PC represents individuals, estates and businesses with federal and state tax controversies, including audits, appeals, litigation and foreign transaction reporting. Collectively, our Boston tax attorneys have more than 100 years of experience investigating and defending IRS and state tax matters.
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