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Monthly Archives: August 2013

Note Held in the US Subject to FBAR Penalty Under 2011 OVDI?

We have a client in the 2011 OVDI program. He has a note, which is physically in the United States, from a foreign obligor. The validity of the note is recognized by the IRS (e.g market rate interest, etc.) and the interest on this note is subject to tax, as well as the borrowings to…
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Why the IRS is Fed Up with Swiss Bankers!

Working with a Swiss lawyer and others, the US businessman father arranged for over $12 million in the undeclared accounts to be left to his surviving spouse and five of his children, including Seggerman. As a result of the successful implementation of that plan, and to hide the undeclared funds from the IRS, Seggerman, who,…
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BVI to comply with US FATCA!

The leader of the British Virgin Islands says the Caribbean territory has started talks with the US Treasury to comply with a law designed to counter offshore tax evasion. The tiny islands are one of the world’s top offshore trust jurisdictions and the incorporated registry for hundreds of thousands of companies. Premier Orlando Smith said August 20,…
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Swiss Banks Agree to Plan to End Past US Tax Evasion Issues!

Swiss banks are ready to pay hefty fines for sheltering United States tax fugitives under the terms of a new deal given the green light by the Swiss government on Wednesday. While official details will not be concluded until the US signs the agreement, both the cabinet and the Swiss Bankers Association (SBA) said the deal should…
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