Robert E. McKenzie comments for Accounting Today on IRS 2012 offshore initiative
On January 11, 2012 National Taxpayer Advocate Nina E. Olson released her annual report to Congress, identifying the combination of the IRS’s expanding workload and declining resources as the most serious problem facing taxpayers. The result, the report says, is inadequate taxpayer service, erosion of taxpayer rights, and reduced tax compliance. The Advocate expressed her continuing concern that the IRS’s expanding use of automated processes to adjust tax liabilities is causing harm to taxpayers and recommended that Congress enact a comprehensive Taxpayer Bill of Rights.
On January 9, 2012 the Internal Revenue Service reopened the offshore voluntary disclosure program to help people hiding offshore accounts get current with their taxes and announced the collection of more than $4.4 billion so far from the two previous international programs.
McKenzie Quoted on Offshore Accounts by Wall Street Journal MarketWatch.
In April the Justice Department filed a lawsuit that sought to force HSBC India to reveal the names of U.S. customers with secret accounts, and a U. S. District subsequently granted the IRS authority to issue John Doe Summons for the names of U. S. residents of Indian descent who have had NRE accounts (Non-resident External Rupee Accounts) at the bank.
Foreign Account Tax Compliance Act (FATCA) Explanation of Section 6038D Temporary and Proposed Regulations Custom Search _______________________________________________________________________________________________ The Foreign Account Tax Compliance Act, enacted in 2010, created new IRC Section 6038D and requires individuals to file a statement with their…
Under the Bank Secrecy Act, U.S. residents or a person in and doing business in the United States must file a report with the U.S. Treasury if he or she has a financial account in a foreign country with a value exceeding $10,000 at any time during the calendar year. Taxpayers comply with this law by noting the account on their tax return and by filing Form 90-22.1, the Foreign Bank and Financial Account Report (FBAR). Willfully failing to file an FBAR report can be punished under both civil and criminal law.
IRS Criminal Investigation (CI) is comprised of approximately 4,400 employees worldwide, approximately 2,600 of which are special agents whose investigative jurisdiction includes tax, money laundering and Bank Secrecy Act laws. While other federal agencies also have investigative jurisdiction for money laundering and some bank secrecy act violations, IRS is the only federal agency that can investigate potential criminal violations of the Internal Revenue Code.
Arnstein & Lehr Chicago Partner Robert E. McKenzie was interviewed by First Business News for its April 11 broadcast. During the interview Mr. McKenzie discussed the IRS tax probe of HSBC Bank off-shore accounts in India. According to Mr. McKenzie,…
Custom Search Arnstein & Lehr Chicago Partner Robert E. McKenzie recently authored a piece titled, "IRS and Offshore Accounts." It discusses the IRS' new 2011 Voluntary Disclosure Initiative (OVDI) for taxpayers to disclose their unreported offshore accounts. To read "IRS…