The Department of Justice Tax Division released commentary and guidance in regards to the Program for Non-Prosecution Agreements (NPA) or Non-Target Letters (NTL) for Swiss Banks.
The commentary reiterated several deadlines and points that are worth mentioning.
The Tax Division of the Department of Justice has open investigations into numerous offshore banks located in Switzerland. These investigations are part of the Program for Swiss Banks (PFSB) as detailed in a joint statement press release by the United States and Switzerland.
It is estimated that hundreds of thousands of American citizens and holders of permanent residency status in the United States live in Israel. While U.S. citizens are required to file reports with the Internal Revenue Service about their incomes and holdings in foreign banks even if they live abroad, it is thought that large numbers of people who have dual American-Israeli citizenship and live in Israel have failed to do so.
Per the Intergovernmental Agreement (IGA) between Canada and the United States, on July 1st, 2014, information sharing between both countries will commence.
All fifty states have worker classification laws. Most states (like the IRS) will fall back on the common law standards that revolve around behavioral and financial control, in addition to the type of defined relationship at the onset of employment and throughout the employment term.
The eligibility requirements for expanded Streamline Filing were published on June 18th, 2014. There are two ways for a taxpayer to engage in Streamline Filing.
Ten Swiss banks have requested to be removed from consideration for non-prosecution agreements offered by the Department of Justice.
If you have undisclosed accounts, this filing process becomes even more complicated. Thankfully the IRS has programs, including Offshore Voluntary Disclosure Program (OVDP) to help reach compliance.
Audit Technique Guides are particularly useful to tax practitioners because they provide a strong foundation when advising clients of audit risk and they point out common areas for mistakes, provide a brief but inclusive overview about typical business practices within a market segment, and are perpetually being updated and changed.
The Secretary of Treasury, Jacob Lew, signed off on changes to the current inversion tax rules in the Internal Revenue Code. These new rules are not retroactive and only affect either pending or future inversions.
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