The American taxpayer has now been put in a full disclosure position by the IRS

New I.R.S. program granting Amnesty from criminal tax prosecution for offshore delinquent taxpayers

 New United States tax laws require strict reporting of foreign assets and establish a new program granting Amnesty from criminal tax prosecution for offshore delinquent taxpayers.

This article is in two portions. The first portion considers the Amnesty program for unreported foreign income and the second portion considers the Foreign Asset Reporting Requirements.

Read full article online by Richard S. Lehman, Esq.

The I.R.S. has gone global

Foreign Financial Institutions – Reporting and Withholding United States Taxes

The New Law generally requires Foreign Financial Institutions (FFIs) to provide information to the Internal Revenue Service (IRS) regarding the Foreign Financial Institutions’ United States accounts (U.S. accounts). It also requires certain Nonfinancial Foreign Entities (NFFEs) to provide information on their substantial United States owners (substantial U.S. owners).

The New Law requires that United States payors vs. Withholding Agent that make payments to Foreign Financial Institutions and Non Financial Foreign Entities to withhold the taxes payable by any U.S. persons who may be responsible for taxes to the United States on these payments.

The law takes a second step and imposes the same withholding tax on certain Foreign Financial Institutions for payments those institutions make to certain accounts that are owned by U.S. taxpayers or presumed to be owned by U.S. taxpayers.  Read full article by Richard S. Lehman, Esq.

New IRS Amnesty Program update

PART 1: New U.S. Tax Laws for 2011, 2012 and 2013


PART 2: Focus on the New IRS Amnesty Program, Foreign estates and foreign trusts, Specified Foreign Financial Assets