International Taxation

1
Jan

Federal Court Authorizes IRS to Issue “John Doe” Summons to UBS

The Internal Revenue Service (IRS) and the U.S. Department of Justice (DOJ) continue to actively seek information about U.S. taxpayers with interests in foreign accounts.  The IRS and the DOJ sought a “John Doe” summons for the Swiss bank UBS AG.  A “John Doe” summons issued to a financial institution generally requests information identifying U.S. taxpayers with account holdings or

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26
Jun

Internal Revenue Service Offers New Guidance on FBAR and OVDP Procedures

The IRS has announced new procedures to aid voluntary disclosures by taxpayers with undisclosed foreign accounts. The new procedures follow the IRS’ January 9, 2012 announcement of the 2012 Offshore Voluntary Disclosure Program (OVDP). The new procedures will allow for resolution of issues related to foreign retirement plans, such as the Canadian Registered Retirement Savings Plan, including allowance of low compliance risk

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25
May

Randall Andreozzi Co-Authors Article on FBARS

Individuals with a financial interest in bank accounts or certain foreign financial accounts must report these accounts, if their cumulative value exceeds a threshold amount. Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts, commonly known as FBAR, is the form which is used to satisfy this reporting requirement. The FBAR form is required to be filed annually

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13
Apr

HSBC Bank Accounts Targets by IRS Offshore Activity Efforts

On April 7, 2011, a United States District Court issued an order permitting the IRS to serve John Doe summonses requesting information from HSBC Bank regarding U.S. taxpayers who hold HSBC accounts maintained in India. The John Doe summonses were authorized on the basis that the IRS had a reasonable basis to believe that a group or class of persons

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11
Feb

IRS Offers New Voluntary Disclosure Program for Offshore Bank Account Holders

On February 8, 2011 IRS Commissioner Douglas Shulman announced a new voluntary disclosure program forU.S. taxpayers with offshore financial accounts. The Offshore Voluntary Disclosure Initiative (OVDI) allows taxpayers with unreported income from offshore financial accounts to properly disclose the income to the IRS in exchange for reduced penalties. The program runs until August 31, 2011. Taxpayers holding an interest in or signature

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11
Jan

WikiLeaks May Impact US Offshore Account Holders

The website, WikiLeaks, has become a controversial news phenomenon. WikiLeaks publishes secret, private, and classified information primarily with respect to government practices. Its recent communication however, brings the impact of its disclosures to the doorsteps of individual citizens. On January 17, WikiLeaks stated that it intends to disclose the foreign bank account information of over 2,000 foreign bank account holders.

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