Posts Tagged ‘Offshore voluntary disclosure initiative’
Attention: U.S. Expats in or Near Vienna, Austria
James C. Sexton, Jr., LL.M., one of my business partners, will be in Vienna Tuesday, June 5, 2012, to deliver a free presentation in English focusing on the U.S. tax and disclosure obligations for U.S. citizens or long-term residents living overseas. It’s entitled “Tax Obligations of U.S. Citizens Living Abroad“ and will focus on assisting U.S. [...]
Growing Numbers of Tax Refugees Exit USA—Permanently
If you’re a U.S. citizen or long-term permanent resident (“green card” holder), you have a unique responsibility: you must pay tax on your worldwide income, even if you live outside the United States. Not to mention capital gains tax, gift tax, and estate tax. Numerous additional obligations come with U.S. citizenship or permanent resident status. [...]
Amended Tax Treaty Effectively Ends Swiss Bank Secrecy for U.S. Clients
Switzerland’s tradition of bank secrecy dates back three centuries. In 1713, the canton of Geneva enacted an ordinance that prohibited bankers from divulging any information about their clients’ transactions. Since then, the Swiss have successfully rebuffed demands to end or restrict bank secrecy from adversaries ranging from Napoleon to Adolph Hitler. But while Napoleon and [...]
IRS Admits Offshore Enforcement Efforts Leading to Soaring Expatriation Rates
Occasionally, the U.S. Congress discovers to its great surprise that the agency it created to collect revenues for the federal government, the Internal Revenue Service, engages in systematic abuse of taxpayers. In one such moment in 1979, Congress created the Office of the Taxpayer Ombudsman as a taxpayer advocate within the IRS. This office eventually [...]
IRS Makes Offshore Voluntary Disclosure Framework Permanent
U.S. permanent residents and all U.S. citizens, no matter where they live, to declare virtually all offshore accounts with an aggregate value of $10,000 or more. Income generated from these accounts is also taxable. I most recently wrote about these obligations here. U.S. citizens living abroad have a unique reporting burden, as no other civilized [...]
Swiss Secrecy Breach: Does the Punishment Fit the Crime?
If you still have the quaint idea that offshore bank secrecy laws have any “teeth” to them, think again. A case in point is the world-famous Swiss bank secrecy law. Article 47 (Art. 47) of the Swiss Banking Act, Paragraph 1 reads as follows: “Whoever divulges a secret entrusted to him or of which he [...]
The IRS Wants Your Electronic Data
Other than the crisis in Europe or Herman Cain’s latest mistress, what else is happening in the world? In case you missed it, on October 18, the IRS issued what’s called a “Chief Counsel Advice” (CCA) concerning what it calls “original electronic data files.” Basically, the IRS now asserts the right to issue a summons [...]
Form 8938: Not a Prelude to a Wealth Tax…This Time [Part II]
In my last blog entry, I described the latest salvo against offshore financial privacy from the IRS: the requirement to file a tell-all form annually with your tax return detailing “foreign financial assets” with an aggregate value exceeding $50,000. The IRS recently issued a draft version of this Form 8938, along with preliminary regulations on [...]