For your reading pleasure, here is Notice 2009-62. If you have signature power over a foreign financial account but the money isn’t yours, then you have an extension of time to deal with the “Come to Jesus!” clean-up and file all of your paperwork with the IRS. If this applies to your particular situation, it [...]
The Swiss government is thinking about the proposed settlement in the UBS litigation. (The settlement would have UBS disclose some names, but not the names of all of its 52,000-ish U.S. customers. Convenient fig leaf for UBS and IRS.) Reuters reports on Swiss cabinet meetings on this point. From the article, we can see a [...]
It’s a giant data sweep. With a defined aim. Unfortunately, the scheme may be turning out badly, if my experience is typical. Here’s the plan: Announce the amnesty. Yell “Scary Monsters!” as loudly and frequently as you can, and get as much press as you can. Taxpayers apply for the amnesty so they can sleep [...]
The IRS process for starting an amnesty application for an offshore bank account has an interesting thing in it. You tell me: sneaky or sloppy? The process up to now The process for an amnesty application up to now has been pretty clean. Start the voluntary disclosure process, go all the way to the end, [...]
Some famous guy said “Those who cannot remember the past yadda yadda.”* So for those of you caught up in the thrills of what the IRS is doing in the current voluntary disclosure program for foreign accounts, here’s a little Blast from the Past, government-style. The official citation is IRS News Release #IR-2003-48. Because lawyers [...]
