by Lance Wallach
According to various reports the IRS is investigating the
Israeli banks Bank Leumi, Bank Hapoalim and Mizrahi Tefahot Bank for conspiring
with individuals to enter into a loan scheme intended to evade taxes on funds
brought to the U.S. from undisclosed foreign bank accounts. The focus on the
banks themselves is a notable departure from similar investigations in the
past. In prior investigations, the bank or bankers had a passive relationship,
whereas Bank Leumi allegedly took an active role in setting up the scheme to
evade taxes. Bank Leumi has sent letters to various account holders suggesting
clients enter into the IRS voluntary disclosure program otherwis
If You Have or Had Money Overseas You Better File for Amnesty ASAP
Known as the
Offshore Voluntary Disclosure Program/Initiative (OVDP or OVDI).
To try to reduce the fines we suggest that you then opt
out and take your case to the IRS appeals division. Our former IRS appeals
officer has lots of experience in this. He was also a manager in the IRS
international division. With large fines at stake you probably want the best.
Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, abusive tax shelters, financial, international tax, and estate planning. He writes about 412(i), 419, Section79, FBAR, and captive insurance plans. He speaks at more than ten conventions annually, writes for over fifty publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Public Radio’s All Things Considered, and others. Lance has written numerous books including Protecting Clients from Fraud, Incompetence and Scams published by John Wiley and Sons, Bisk Education’s CPA’s Guide to Life Insurance and Federal Estate and Gift Taxation, as well as the AICPA best-selling books, including Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots. He does expert witness testimony and has never lost a case. Contact him at 516.938.5007, wallachinc@gmail.com or visit http://www.taxadvisorexpert.com.
The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.
Google Lance Wallach for more
ReplyDeleteCaptive Insurance & 419 Plans Litigation
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MONDAY, OCTOBER 21, 2013
A pure captive insurance company
A pure captive insurance company is an insurance company created by the owners of an operating business to provide supplemental property and casualty insurance to such operating business. The shares of the captive insurance company can be owned by owners of the operating business or an irrevocable trust for the benefit of such owner’s heirs.
ReplyDeleteWednesday, May 8, 2013
FBAR QUESTIONS
Lance Wallach
Acquired or inherited foreign stock or securities, such as bonds.
Do I need to report these on Form 8938?
Foreign stock or securities, if you hold them outside of a financial account, must be reported on Form 8938, provided the value of your specified foreign financial assets is greater than the reporting threshold that applies to you. If you hold foreign stock or securities inside of a financial account, you do not report the stock or securities on Form 8938. For more information regarding the reporting of the holdings of financial accounts, see FAQs 8 and 9.
I directly hold shares of a U.S. mutual fund that owns foreign stocks and securities.
Do I need to report the shares of the U.S. mutual fund or the stocks and securities held by the mutual fund on Form 8938?
If you directly hold shares of a U.S. mutual fund you do not need to report the mutual fund or the holdings of the mutual fund.
I have a financial account maintained by a U.S. financial institution (including U.S. mutual funds, IRAs and 401(K) Plans) that holds foreign stock and securities.
Do I need to report the financial account or its holdings?
You do not need to report a financial account maintained by a U.S. financial institution or its holdings. Examples of financial accounts maintained by U.S. financial institutions include:
U.S. Mutual fund accounts
IRAs (traditional or Roth)
401 (k) retirement plans
Qualified U.S. retirement plans
Brokerage accounts maintained by U.S. financial institutions
The information provided herein is not intended as legal, accounting, financial or any type of advice for any specific individual or other entity. You should contact an appropriate professional for any such advice.