Post on 16-Dec-2015
transcript
Offshore Investing
• Benefits of Offshore Investing
• Higher Return on Investment (ROI)
• Mitigate Risk
• Convenience
• Tax Shelters
Offshore Investing
• Failure to comply could:
• Negate profits & result in loss of investment• Deem your activities illegal• Result in large monetary fines (possibly more
than your investments, everything that you have or will have)
• Result in loss of green card• Destroy your legacy
Your Duties
• FBAR (Foreign Bank Account Reports Form TD F 90-22.1)• Penalty
• Reporting Foreign Income Generated from Offshore Financial Institution• Who is Taxed?
• Taxes Covered • Interest Income Generated From Foreign Account• Special Rules for Foreign Mutual Funds
Passive Foreign Investment Company (PFIC)
• What is a PFIC?
• Significance of PFIC Tax
• Avoiding PFIC Rules• QEF Election• Market to Market Election
Liabilities
• Tax Liability Associated With Foreign Account
• Criminal Penalties Associated with Not Disclosing Income• Attempt to Evade the Payment of Tax• Filing of a False and Fraudulent Tax Return
• Civil Penalties
United States (U.S.) Enforcement
• Why and How?
• Bank Summons
• Basler Kantonalbank• Credit Suisse Group AG & Privite Advisors• HSBC• Israeli Bank• Neue Zaercher Bank• UBS AG & Swiss Financial Advisers AG• Bank Hapoalim• Cantonal Banks
• Joint Country Criminal Investigation
United States (U.S.) Enforcement (cont.)
• Government Data/Revenue Collection Programs• OVDI & OVDI II
• Criminal Prosecutions• Charges• Convictions & Pleas
• Civil Enforcement• Audits• 3rd Party Information• Criminal Consequences
United States (U.S.) Enforcement (cont.)
• Immigration Problem
• Deportation• Federal or State Tax Crime• Incarceration • Fines
Unfiled Tax Returns
• Statute of limitations:• Criminal• Civil
• Lost records
• Basis [adjusted cost] of assets sold
What if you can’t pay?
• Additional time to pay
• Installment payment plans
• Offer In Compromise (OIC)
• Bankruptcy• Liquidation [Chapter 7]• Reorganization [Chapters 11 & 13]
What You Can Do!
• IRS Voluntary Disclosure• Amnesty Programs
• State Considerations
• Dual Citizenship Consideration
How We Can Help
• Over 30 years protecting your rights in Tax Law
• Review your accounts
• Help you comply with the law
• Determine best approach to deal with U.S. Government