IRS is on a Mission is to Reduce the Tax Gap
The difference between the amount of tax owed by Taxpayers for a given year and the amount that is actually paid timely for that same year is known as the “Gross Tax Gap”. The IRS looks at this number as an estimate of the annual amount of noncompliance with the US tax laws. In the […]
Out of Compliance Taxpayers Beware of The J5
In 2017, following the Panama Papers and Paradise Papers data leaks, the Organization for Economic Co-operation and Development (OECD) issued a “call to action” for countries to do more to tackle enablers of tax crimes. The result of this “call to action” was the 2018 establishment of an operational alliance known as the “Joint Chiefs […]
FinCEN is seeking Feedback on the Corporate Transparency Act (CTA)
The CTA is a recent reporting requirement that is expected to enhance U.S. national security through increasing the difficulty involved for harmful actors to exploit opaque legal structures for laundering money, financing terrorism, proliferating weapons of mass destruction, trafficking humans, and drugs, and committing tax fraud and other crimes. Included in the AML Act of […]
Closing a Foreign Bank Account will not solve a Taxpayer’s Disclosure Problem
IRS is interested in U.S. Taxpayer financial accounts everywhere in the world. If the IRS learns that a Taxpayer has undisclosed reportable accounts or income before a US Taxpayer reports them, the Taxpayer can face serious consequences including criminal prosecution. Taxpayers under the impression that closing a foreign bank account today will solve a lack […]
Have you hired the right Tax Preparer to prepare your Taxes?
Tax Season is here. Tax Preparers have different levels of skills, education and expertise and Taxpayers ought to take a closer look at what constitutes a “Qualified” Tax Preparer. There are various types of regulated Tax Preparers, including Certified Public accountants (CPAs), Enrolled Agents, and Attorneys. CPAs, Enrolled Agents and Attorneys are “Qualified” by IRS […]
19 possible Questions that your Tax Preparer ought to Ask regarding Foreign Accounts and Assets
Many Taxpayers with international entanglements seek the assistance of tax return preparers without U.S. international tax reporting experience. Because US International tax reporting is complicated and often overwhelming for US Taxpayers, international tax specialist CPA is the appropriate choice for the work. When an inappropriate US international income tax compliance preparer is not hired, the […]
Will the Perception of the USA as a Preferred Tax Haven be Jeopardized Going Forward?
Changes to the Bank Secrecy Act incorporated into the National Defense Authorization Act (NDAA) contain requirements for beneficial ownership disclosure by covered legal entities at the time of their creation for inclusion in a database that will be accessible by USA and foreign law enforcement, regulators, and AML compliant US financial institutions. Why is there […]
New Criminal Offenses related to Foreign Political Figures and Money Laundering Entities
Regarding assets belonging to Senior Foreign Officials, Section 6313 of the AML Act of 2020 prohibits the concealment of the source of those assets in monetary transactions or involving Institutions of primary Money Laundering concern as two new criminal offenses. Both offenses are punishable by a fine of up to $1,000,000 or 10 years of […]
Treasury Attachés, Foreign Financial Intelligence Unit Liaisons and Foreign Financial Institutions
The AML Act of 2020 includes the creation of “Treasury Attachés” (SEC. 6106, appointed by the US Treasury Department) and the “Foreign Financial Intelligence Unit Liaisons” (SEC. 6108, appointed by FinCEN) to be stationed abroad. The Treasury Attachés will: Assist the Department of the Treasury with developing and executing the financial and economic policy of […]
Foreign Bank and the New Longer Arm of the US Treasury and DOJ
Before passage of the AML ACT of 2020 (the “ACT”), The US Department of the Treasury, and the US Justice Department (DOJ) had US legal authority to subpoena foreign banks with US correspondent accounts for related US records including records held in a foreign country. AML ACT of 2020 expands the subpoena reach of the […]
Should Banks Continue To Do Business with Entities for Which a SAR is Filed?
Should Banks Continue To Do Business with Entities for Which a SAR is Filed? This article appeared at the Daily Business Review on 12/23/20
After Ten Years, FATCA is NOT GOING AWAY!
FATCA was signed into law in March 2010 with the objective of combating international income tax reporting non-compliance by US citizens and U.S. taxpaying residents (US Taxpayers). It requires Foreign Financial Institutions (FFIs) to annually report the reportable balances and income in the accounts held by their US customers to the IRS. It requires US […]
