by Phil Hodgen, Hodgen Law Group PC on February 17, 2010
For those of you who aren’t checking my main blog regularly:
The Geithner effect and offshore bank account enforcement (my point there is that the IRS is making people fear them yet people are willing to cheat more — “keep doing what you’re doing and you’ll keep getting what you’re getting” is the moral of THAT [...]
by Phil Hodgen, Hodgen Law Group PC on December 16, 2009
The Economist has a short article about the ongoing Italian offshore account amnesty. Look carefully for the penalty: Five. Percent.
ITALIANS are reckoned to have around €300 billion ($440 billion) of assets stashed abroad. The government would like to lure them back, or at least recoup some of the taxes it has lost [...]
by Phil Hodgen, Hodgen Law Group PC on December 14, 2009
I’ve posted on the main site about the theft of client data from HSBC in Geneva. This one is aimed at French customers of HSBC.
Secrecy is a doomed tax strategy. It may be now, or it may be later. But sooner or later secrecy will fail you. (Or if [...]
by Phil Hodgen, Hodgen Law Group PC on November 17, 2009
The information is trickling out about the criteria used to select UBS customers for revelation to the IRS. See Jack Townsend’s post, with links and the usual helpful commentary. The criteria largely follow what I blogged before, but with additional detail.
by Phil Hodgen, Hodgen Law Group PC on November 6, 2009
Thanks to someone who will remain nameless, here is an article showing the criteria by which the IRS queried UBS for names of American customers:
In German
The Google Translate version follows:
SWITZERLAND SACRIFICE UBS CLIENTS
The American tax authorities are not only the data from UBS tell customers, but also those of the participating Swiss asset manager. [...]
by Phil Hodgen, Hodgen Law Group PC on October 19, 2009
Go to my main blog for a post on a call I received this morning from a gentleman who missed the deadline for disclosing signature control over a foreign bank account:
Low balance in the account — high enough to trigger the reporting requirement but low enough so you wonder why the IRS would even care;
It’s [...]
by Phil Hodgen, Hodgen Law Group PC on October 15, 2009
Yes it is possible to do this and–if things go as hoped–maintain the privacy you expected. I know of a reasonable-sized group of U.S. account holders doing this. I wish them well. It postpones the inevitable, as far as I’m concerned. But maybe you want to do this. Maybe you [...]
by Phil Hodgen, Hodgen Law Group PC on October 14, 2009
Here’s a lightly adapted version of the letter we use. If you want to launch your own voluntary disclosure for your offshore account, here’s what to do:
Go to the IRS website and find the address and phone number for the IRS Criminal Investigations office for where you live.
Call them and get their fax number.
Do [...]
by Phil Hodgen, Hodgen Law Group PC on October 14, 2009
We are getting calls today asking for help. Sorry. We can’t take on another amnesty filing because we have to hit FedEx tonight. Sorry. Limited bandwidth. Four people working nonstop to get paper out the door.
If you want to go forward with the voluntary disclosure program, launch it yourself (look [...]
by Phil Hodgen, Hodgen Law Group PC on October 13, 2009
Given the impending deadline, I’ve received some questions about whether the further extension to June 30, 2010 will apply to give relief to people who are possibly required to file Form TD F 90-22.1.
No deep comments at the moment. Too busy. Read it then go tell the IRS that they need a good [...]
