Global Tax Enforcement

Global Tax Enforcement

Commentary on Tax Enforcement, News and Developments

Category Archives: HSBC

Subscribe to HSBC RSS Feed

IRS and DOJ Losing Patience with Taxpayers with Undisclosed Foreign Accounts

Posted in HSBC, Tax Controversy, UBS, Voluntary Disclosure
The assistant US attorney general for the Tax Division, Kathryn Keneally, recently indicated that the window for avoiding criminal prosecution related to undeclared foreign accounts may be closing soon.  At a roundtable discussion at the University of Southern California’s annual tax institute, Ms. Keneally indicated that waiting to disclose offshore accounts is extremely dangerous.  If … Continue Reading

IRS Issues Updated Guidance for 2012 Offshore Voluntary Disclosure Program

Posted in FATCA, HSBC, Tax Controversy, UBS, Voluntary Disclosure
On June 26, 2012, the Internal Revenue Service (“IRS”) released new FAQ’s on the current Offshore Voluntary Disclosure Program (“OVDP”) . The IRS opened the current OVDP on January 9, 2012, but, other than announcing the new FBAR penalty of 27.5%, had not issued updated guidance, leaving practitioners and taxpayers to rely on the 2011 … Continue Reading

Careful Attention to Offshore Voluntary Disclosure Cases

Posted in HSBC, Tax Controversy, Tax Fraud, UBS, Voluntary Disclosure
Baker Hostetler’s lawyers have handled hundreds of voluntary disclosures through the 2009 and 2011 Offshore Voluntary Disclosure Programs (OVDI).  Recently, the IRS has announced a third OVDI, this time with no defined termination date. The OVDI programs provide important protections for those who might face criminal prosecution for unreported income or unfiled informational returns.  The … Continue Reading

IRS Announces A Third Voluntary Disclosure Initiative

Posted in HSBC, UBS, Voluntary Disclosure
The IRS formal program for making voluntary disclosures of offshore accounts and unreported foreign income has been reopened.  This is the third in a series of voluntary disclosure programs announced by the IRS.  This newest program reinstates fixed penalty amounts for taxpayers who agree to amend prior tax returns and pay taxes due and file … Continue Reading

IRS Grants Additional Time To File FBARs

Posted in HSBC, Tax Controversy, Tax Fraud, UBS, Voluntary Disclosure
Today, the IRS announced an extension until November 1, 2011 for taxpayers who did not file TD F 90-22.1 (FBARs) forms in prior years.  For those taxpayers who only had signatory authority over a foreign account and did not own the account in 2009 or prior years, additional time has been granted to gather the necessary information … Continue Reading

John Doe Summons Granted for US Account Holders at HSBC

Posted in HSBC, Tax Fraud, UBS, Voluntary Disclosure
The U.S. District Court for the Northern District of California has granted the Department of Justice request to allow the IRS to issue a John Doe Summons on HSBC-India.  The government seeks records of U.S. taxpayers who hold accounts at the bank.  The evidence supporting the court petition suggests HSBC India was engaged in activity that … Continue Reading