Category: Voluntary Disclosure Program

New IRS offshore amnesty regime imposes bigger penalties for secret accounts

The US Internal Revenue Service (IRS) has issued guidance on the voluntary disclosure regime now in force, following the termination of its offshore predecessor on 28 September 2018. The new rules are effective for all disclosures after that date. And the possible penalties have gone up quite significantly. One of...

Nigeria’s Tax Law obsolete, overdue for review —Oruaze Dickson

A legal practitioner cum entrepreneur, Moses Oruaze Dickson, has called for the review of the legislative framework for tax and taxation in the country, describing the existing law as obsolete for a progressive society like Nigeria. According to Dickson, who is also Managing Solicitor, Triax Solicitors, the law is long...

Voices The IRS is taking off its velvet gloves for offshore holdings

Ferreting out people who want to hide their assets and income overseas is nothing new for the Internal Revenue Service. And for roughly nine years, the agency has sponsored programs tailored to those taxpayers who were prepared to come forward and disclose their unreported foreign assets and income in exchange...

CRA finalizes new Information Circular for income tax Voluntary Disclosures Program

On December 15, 2017, the CRA released the final version of Information Circular IC 00-1R6 – Voluntary Disclosures Program (“VDP”) for income tax, after receiving and considering community input on the June 2017 draft version. This article summarizes the important differences between the draft and the final ICs and discusses...

Israel Tax Authority reintroduces voluntary disclosure

Ahead of the CRS agreement, the procedure enables Israelis to disclose unreported income without facing criminal proceedings. As reported last month by “Globes,” ahead of the anticipated implementation of the Common Reporting Standard (CRS) agreement for automatic exchanges of information between tax authorities, and given the Israel Tax Authority’s stepped...

Hapoalim Canadian customers say bank aided tax evasion

114 taxpayers in Canada’s voluntary disclosure program say that the Israeli bank helped them evade taxes. As if the headache of the investigation by US authorities were not enough, Bank Hapoalim (TASE: POLI), managed by CEO Arik Pinto, discovered two days ago that Canada was also taking aim at it....

New Dutch Law Leaves Repentant Taxpayers Out in the Cold

The abolition of a scheme allowing Dutch taxpayers to fess up to their tax sins and avoid criminal charges is likely to discourage high-net worth individuals from ever disclosing money hidden abroad to local authorities, practitioners say. Deputy Minister of Finance Eric Wiebes announced that it was time to draw...

United States: California Expands Voluntary Disclosure Program for Out‑of‑State Trusts

At a Glance… On September 25, Governor Brown signed into law Senate Bill No. 813, which updated the California Voluntary Disclosure Program (VDP) to include out-of-state trusts with California beneficiaries and non-resident partners of out-of-state partnerships, and to allow the Franchise Tax Board (FTB) to waive the S Corporation or...

Voluntary offshore disclosures: Final SARS deadline fast approaches

JOHANNESBURG — Despite question marks hanging over SARS, its chief Tom Moyane and the institution’s current ability to effectively collect taxes, the authority continues to push ahead with expanding its international net. A 31 August deadline for taxpayers to disclose their offshore assets and income to SARS is fast approaching....

SA taxpayers with offshore cash, assets given deadline to disclose info

The Common Reporting Standard (CRS) allows for the automatic exchange of information between tax authorities. Local taxpayers who may have stashed their assets in cash and property offshore have a month to disclose their earnings and ownership details to the South African Revenue Services (Sars). The deadline for the Special...

Tax on offshore investments: time to come clean

The South African Revenue Service (SARS) launched the Special Voluntary Disclosure Programme (SVDP) in October 2016, providing taxpayers with the opportunity to make good on any tax and/or exchange control contraventions of which they may be guilty in relation to offshore investments. The nine-month window period opened on October 1,...

Bills, cars, bank accounts: the Italian Revenue Service will chase evaders who pretend to be abroad

The Italian Revenue Agency is stepping up its fight against international tax evasion. The tax authority will focus on undeclared funds and income held abroad by Italian taxpayers who have become resident abroad since January 1, 2010. Controls will be based on selected lists, which will first target the most...

Canada To Ramp Up Efforts Against Tax Evasion

The Canadian Government has said that it will review its tax ruling process and voluntary disclosures program as part of its response to recommendations made last year by a parliamentary committee. In October 2016, the Standing Committee on Finance released its report on the Canada Revenue Agency’s (CRA’s) efforts to...

Canada: Report On The Voluntary Disclosures Program (VDP) – Canadian Tax Consultant Analysis

The Offshore Compliance Advisory Committee issued a report in December 2016 to the Canada Revenue Agency about the Voluntary Disclosures Program (VDP or tax amnesty). If a taxpayer submits a successful income tax or GST/HST voluntary disclosure program application then generally criminal income tax prosecution and civil tax penalties under...

Automatic Exchange of Information and Common Reporting Standards in Malaysia

In efforts towards global transparency, over 100 countries have agreed to automatically exchange information relating to financial accounts (AEOI) with each other under the Convention on Mutual Administrative Assistance in Tax Matters (Convention). The OECD had also developed the Common Reporting Standards (CRS) which set out the common information to...

South African Tax Bills Approved By Parliament

South Africa’s Ministry of Finance has published the 2016 Taxation Laws Amendment Bill (TLAB), which has received parliamentary approval and gives effect to the tax changes announced in the Budget in February this year, together with legislation confirming the final details of the Special Voluntary Disclosure Program (SVDP). With changes...

CRA must toughen up voluntary disclosure for tax cheats, panel says

The Canada Revenue Agency needs to toughen up the program that offers advantageous deals to tax cheats, especially in cases where large amounts of income were not declared through deliberate schemes, a federally appointed committee says. In a report released Thursday, the Offshore Compliance Advisory Committee called for a series...

Canadians in Panama Papers shouldn’t expect a tax deal, CRA says

More than 2,000 files under review, 85 taxpayers under audit National Revenue Minister Diane Lebouthillier said in a statement Monday that a few thousand files are now being pursued by the tax agency after it sifted through the Panama Papers. Canadians implicated in the Panama Papers shouldn’t expect any leniency...

IRS Overlooks Noncompliance in Offshore Voluntary Disclosure Program

The Internal Revenue Service is missing out on imposing approximately $21.6 million in penalties on taxpayers who are denied entry or withdraw from its Offshore Voluntary Disclosure Program, according to a new report The report, from the Treasury Inspector General for Tax Administration, found the IRS needs to improve its...

IRS Uses New Tactic to Expand Efforts to Combat Offshore Tax Evasion

In a search for financial records of a U.S. taxpayer who allegedly parked undeclared income offshore, the Internal Revenue Service (IRS) and the U.S. Department of Justice (DoJ) are seeking to enforce a summons against a U.S. branch of a foreign bank for records held by a foreign branch of...

Canada Revenue offered amnesty to wealthy KPMG clients in offshore tax ‘sham’

Federal authorities demanded secrecy in no-penalty, no-prosecution deal to high net worth Canadians The Canada Revenue Agency offered amnesty to multi-millionaire clients caught using what’s been called an offshore tax “sham” on the Isle of Man — a reprieve that was supposed to remain secret and out of the public...

IRS lists hiding money, income offshore on ‘Dirty Dozen’ tax scams

ST. GEORGE — The Internal Revenue Service has announced that avoiding taxes by hiding money or assets in unreported offshore accounts remains on its annual list of tax scams known as the “Dirty Dozen.” “Our continued enforcement actions should discourage anyone from trying to illegally hide money and income offshore,”...

Canada: Voluntary Disclosure CRA Latest Statistics – Toronto Tax Lawyer Commentary

Voluntary Disclosure & CRA Annual Report to Parliament – General Information CRA has provided the latest statistics about the tax amnesty or voluntary disclosure program (VDP) for the previous fiscal year. CRA provides an annual report to parliament that provides a wealth of information about its activities over the past...

Another chance for taxdodgers to come clean

The announcement of another tax and exchange control amnesty in this year’s budget is keenly awaited by some South African taxpayers. The looming implementation of the Common Reporting Standard for the automatic exchange of financial information between more than a hundred countries seems to be fueling the desire for another...

US Justice Department Announces Resolution Under Swiss Bank Program With Union Bancaire Privée, UBP SA

The Department of Justice announced today that Union Bancaire Privée, UBP SA (UBP), reached a resolution under the department’s Swiss Bank Program. UBP will pay a penalty of more than $187 million. “Today’s agreement marks the final resolution with UBP, which acknowledges its role in conspiring with U.S. taxpayers to...

United States: Global Tax Enforcement in 2016: What You Need To Know

The investigation and prosecution of tax evasion has, in the last decade, grown from a specialized subcategory of law enforcement into a first-tier policy concern for the global community. Starting with the U.S. government’s crackdown on Swiss bank UBS in 2008, there has been a steady drumbeat of news about...

As Offshore Banks Agree To U.S. Tax Evasion Deal, Account Holders Must Deal With IRS

Lately, the IRS is warning offshore account holders to disclose before it’s too late. Under FATCA, banks everywhere want to know if you are compliant with the IRS. And the cost of compliance for many people is growing. The IRS updated its list of foreign banks where accounts trigger a...

United States: Is Julius Baer Group AG The Next Swiss Bank To Resolve Its Tax Problems With The U.S.? If So, What Does It Mean To Those Who Had A JB Account?

Shortly before New Year’s, on Wednesday, December 30, 2015, the media reported that Julius Baer Group AG (“JB”) expected to pay about $547 million to settle the U.S. investigation into how the bank (and its bankers) assisted U.S. taxpayers in evading tax. This investigation began more than 4 years ago,...

Global dragnet puts pressure on tax evaders as year-end deadlines loom

Tax cheats are facing a series of year-end deadlines to come clean, as an international dragnet affecting both wealthy Canadians with offshore accounts and Americans in Canada who have failed to file U.S. tax returns keeps tightening. Lawyers say some Canadians with Swiss bank accounts have received letters demanding written...

Mexican Tax Reforms for 2016

On Nov. 18, 2015, reforms to the Mexican Income Tax Law (MITL), Tax Code, Excise Tax and Federal Income Law for 2016 (collectively, the Tax Reform) were published in the Federal Gazette. The Tax Reform reestablishes measures to promote savings and increase incentives for doing business in Mexico, some of...

SARS Explains 2015 Tax Administration Amendments

On December 17, the South African Revenue Service (SARS) issued an explanatory memorandum on the 2015 Tax Administration Laws Amendment Bill (TALAB). In particular, the memorandum looks at the TALAB provisions giving effect to the collection of information from South African financial institutions (FIs), and the associated obligation on the...

US Justice Department Announces Joint Resolution With Two Banks Under Swiss Bank

The Department of Justice announced today that Edmond de Rothschild (Suisse) SA and Edmond de Rothschild (Lugano) SA (collectively EdR Switzerland) reached a joint resolution under the department’s Swiss Bank Program. EdR Switzerland will pay a penalty of more than $45 million. The Swiss Bank Program, which was announced on...