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• Foreign Assets; What Must I Disclose?

  Beginning with income tax returns for 2011, U.S. individual taxpayers must attach a statement (Form 8938) to their return if they hold an interest in “specified foreign financial interests” and the value of those interests exceed certain thresholds. Example for an individual the threshold is $50,000 at year end or $75,000 at anytime during the [...]

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• Offshore Assets and 2011 Disclosure a Volatile Mix

  The IRS Frequently Asked Question 47 which is part of the explanation of the Offshore Voluntary Disclosure Initiative has an ominous warning for taxpayers with undisclosed foreign accounts and more. FAQ 47 it directed to tax return preparers and provides as follows: I have a client who may be eligible to make a voluntary disclosure. [...]

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• FBAR Conviction of NJ MD Affect Dual Nationals

  On January 11, 2012 Michael Reiss, a physician from NJ was sentenced in for failing to report offshore (Swiss) bank accounts (11:CR:0068),United States District Court SDNY. The sentencing memos of the U.S make some important policy statements. The policy statements are: First, Dr. Reiss made no effort to enter the IRS Voluntary Disclosure Program (OVDP) [...]

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• New Offshore Traps

  The U.S. uses a global approach to income and estate tax. Many of the other G-20 countries use a territorial system. The result is that U.S.taxpayers, are now faced with enhanced disclosure and enforcement issues. Form 8938 is required for U.S. taxpayers as part of Form 1040 whose aggregate “specified foreign financial assets” exceed specified [...]

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