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Monthly Archives: May 2014

Lowering the Bar For Willfulness For FBAR Penalties

The IRS has authority to assert FBAR civil penalties.  Before delving into the FBAR abyss, this is a good time to debunk some FBAR myths.  First, there is no such thing as an FBAR penalty within the Offshore Voluntary Disclosure Program (OVDP).  The FBAR penalty exists only outside of the OVDP framework.     However, there…
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Credit Suisse Cuts Deal With US DoJ & They Spin Off Vulnerable Units

We had previously postedAre You A Credit Suisse Client? You May Really Want to Make Your Voluntary Disclosure NOW! where we discussed that the founder of a Swiss trust pleaded guilty to helping Americans evade taxes and said Credit Suisse Group AG was involved in the scheme, adding to its pressure as it tries to resolve…
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10 More FATCA Agreements, Bringing the Total to 62!

tent Since our post of  Thursday, May 1, 2014 "52 Fatca Agreements ... Israel Reached & Australia Signed FATCA Agreements:" 10 more countries have entered into FATCA agreements with the United States, bringing the total to 62!See Below For Types of FATCA Agreements signed by each country and Links to the actual Agreements. Do You Have Unreported Foreign Income?…
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