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Posted on 6/5/14 at 11:23 am to Tiger n Miami AU83
I bet it wouldn't be humorous to those attorneys clients if they knew an accountant was doing any substantial planning. Like I said...malpractice. That is scary.
Posted on 6/5/14 at 11:26 am to BBONDS25
quote:I bet it wouldn't be humorous to those attorneys if they knew their accountant was claiming he does any substantial planning
I bet it wouldn't be humorous to those attorneys clients if they knew an accountant was doing any substantial planning
This post was edited on 6/5/14 at 11:27 am
Posted on 6/5/14 at 11:26 am to BBONDS25
Of course a partner reviews everything. But do you really think you are even ten percent as qualified, capable, or knowledgeable as me because you took an international tax course in law school while I have spent years specializing in it, reading it, and applying it in complex situations in the real world?
I really do have to laugh at that.
Posted on 6/5/14 at 11:28 am to Tiger n Miami AU83
you know what they say about assumptions
Posted on 6/5/14 at 11:29 am to Tiger n Miami AU83
Also, I would bet whatever you wanted that we could take me andyou and sit us down for 1 hour with an international client and discuss his wordwide operations and structuring and tax exposure and ideas and at the end of it, he would hire me not you.
Posted on 6/5/14 at 11:44 am to Tiger n Miami AU83
:Internet badass:
Posted on 6/5/14 at 11:45 am to Tiger n Miami AU83
quote:As a client, if an accountant proposed to singlehand a project like that, it would be an extremely short meeting. I cannot fathom someone with substantial resources feeling differently.
I would bet whatever you wanted that we could take me andyou and sit us down for 1 hour with an international client and discuss his wordwide operations and structuring and tax exposure and ideas and at the end of it, he would hire me not you.
Posted on 6/5/14 at 11:52 am to BBONDS25
quote:Not even.
:Internet badass:
Facts not in evidence BB. I appreciate the claims of expertise. You alluded to having seen evidence of it in some thread. I haven't.
That's not saying it is not there or that the guy is not an IRL expert. But I've not seen it here. Just as with TUba's claim of a PhD. Maybe so. It's just nonevident on this board.
Posted on 6/5/14 at 11:52 am to NC_Tigah
Well, I would want whoever is better at what I needed done, but that's me.
I spent plenty of time when I was at PwC fixing attorney structuring frick ups or telling the client there was no fix because they hired a dumbass attorney that was out of their element.
Law firm I work for now is pretty top notch though.
I spent plenty of time when I was at PwC fixing attorney structuring frick ups or telling the client there was no fix because they hired a dumbass attorney that was out of their element.
Law firm I work for now is pretty top notch though.
Posted on 6/5/14 at 11:59 am to NC_Tigah
quote:I would think that the reporting requirements are intended for people to have a) legitimately received the money and b) to have paid taxes on it already due to it being subject to US taxes.
Pfffssssssttt . . . . here's a secret:
People who "stash their money" in any bank, do not pay taxes on it.
Why?
Because it is not earning money. There is no income.
Posted on 6/5/14 at 12:15 pm to Tiger n Miami AU83
quote:Externally or internally structured?
I spent plenty of time when I was at PwC fixing attorney structuring frick ups
quote:PWC is pretty top-notch.
Law firm I work for now is pretty top notch though.
Posted on 6/5/14 at 12:20 pm to mmcgrath
Reporting requirements are primarily intended to make sure people report earnings from money in offshore accounts.
If it is in a US account, the US financial institution will report earnings and gains and losses both to the owner and irs on a 1099.
Foreign banks have never reported anything to the irs. It has always been the "honor system" for US persons to report earnings like interest and dividends and gains and losses from money they invest with foreign banks.
However, US people have been putting their money in foreign banks for decades and not reporting the earnings. Pissed off US financial institutions and the IRS.
Then in 2008 a UBS (swiss bank) got in trouble with the US department of justice for soliciting wealthy Americans to put their money in UBS instead of US accounts. To save his arse, he agreed to turn over the names of some wealthy Americans that he had helped. Turns out lots of swiss banks had complex setups where they came to the US, and solicited people. Sometimes they wouldfly the US people to Europe, meet them at airport, take their bags of cash and open accounts. They had all different methods.
So, the IRS and the department of justice teamed up to go after these banks. They had a good plan too that I won't go into in detail, but it worked. A lot better than anyone expected.
By 2010, congress saw the billions in taxes collected since 2008 due to what the irs did. So congress passed a law called Fatca.
Fatca is now making it about impossible to move money offshore and not have it reported by the foreign banks which are all pretty much falling in line and cooperating. Especially after several of the swiss banks have paid billions to the US in fines already.
If it is in a US account, the US financial institution will report earnings and gains and losses both to the owner and irs on a 1099.
Foreign banks have never reported anything to the irs. It has always been the "honor system" for US persons to report earnings like interest and dividends and gains and losses from money they invest with foreign banks.
However, US people have been putting their money in foreign banks for decades and not reporting the earnings. Pissed off US financial institutions and the IRS.
Then in 2008 a UBS (swiss bank) got in trouble with the US department of justice for soliciting wealthy Americans to put their money in UBS instead of US accounts. To save his arse, he agreed to turn over the names of some wealthy Americans that he had helped. Turns out lots of swiss banks had complex setups where they came to the US, and solicited people. Sometimes they wouldfly the US people to Europe, meet them at airport, take their bags of cash and open accounts. They had all different methods.
So, the IRS and the department of justice teamed up to go after these banks. They had a good plan too that I won't go into in detail, but it worked. A lot better than anyone expected.
By 2010, congress saw the billions in taxes collected since 2008 due to what the irs did. So congress passed a law called Fatca.
Fatca is now making it about impossible to move money offshore and not have it reported by the foreign banks which are all pretty much falling in line and cooperating. Especially after several of the swiss banks have paid billions to the US in fines already.
Posted on 6/5/14 at 12:27 pm to NC_Tigah
Externally. Generally people relying on either foreign counsel or US attornies who were not international tax specialists.
Most US attorneys that specialize in international tax are pretty top notch.
Most US attorneys that specialize in international tax are pretty top notch.
Posted on 6/5/14 at 3:09 pm to NC_Tigah
Brief response to a couple of points/questions. Don't have time to go into a lot of detail, my early posts were at lunch and I'm busy now. But I promised a response to a legit question...
It is a big deal. Has been for a while now.
This really deserves a long detailed response which I would really like to give. But for now, I try and hit the high points.
Since the IRS started going after these accounts, hundreds of thousands have been disclosed and billions in taxes and penalties paid.
I'm on the front lines with this and have been for the past 4 years. People are still coming forward to disclose accounts and make late filings constantly. I can't get into specifics, but understand this, every week or so, their is a new client in my office wanting to know what to do. I have more work than I can handle and don't need anymore right now. I'm way behind on this stuff as it is now. And the IRS is way behind. They are still processing disclosure cases from years ago. Millions are still flowing into government coffers due to these late disclosures weekly (probably daily if you took the sum total last year divided by 365) if I had to hazard a guess.
Maybe you ask why this is happening. Your answer is one word: FATCA. That's it. It is that simple.
U.S. persons will have all their foreign accounts disclosed by FATCA by next year. You think the number of remaining undisclosed foreign accounts is under 5,000? I think it is closer to 50,000. You said you have one of these. If it is over $10,000 you probably know the penalty for not disclosing it can be $10,000. It can be less under present mitigation guidance, but it can be a lot more if it is a willful violation. Up to the IRS just taking the money in the account (yes, congress has given them the authority and they have written a penalty structure that actually allows this).
That is why FATCA is a BFD and why you are very very wrong thinking this is just some propaganda deflection by the IRS. I can assure you it is not. It is a cash cow for the IRS that still has a lot of milk left in it.
And none of the above is legal advice. It is just the ramblings of an uneducated individual throwing darts at the wall, FTR.
quote:
I understand you apparently view American accounts yet to be identified in 77,000 banks in 70 countries as a BFD -- presumably numerous and voluminous.
It is a big deal. Has been for a while now.
quote:
My guess, and it's only a guess, is that newly discovered undisclosed accounts among those 77,000 banks in 70 countries will total <5000 on top of those previously identified.
You seem to be under a different impression. Why?
This really deserves a long detailed response which I would really like to give. But for now, I try and hit the high points.
Since the IRS started going after these accounts, hundreds of thousands have been disclosed and billions in taxes and penalties paid.
I'm on the front lines with this and have been for the past 4 years. People are still coming forward to disclose accounts and make late filings constantly. I can't get into specifics, but understand this, every week or so, their is a new client in my office wanting to know what to do. I have more work than I can handle and don't need anymore right now. I'm way behind on this stuff as it is now. And the IRS is way behind. They are still processing disclosure cases from years ago. Millions are still flowing into government coffers due to these late disclosures weekly (probably daily if you took the sum total last year divided by 365) if I had to hazard a guess.
Maybe you ask why this is happening. Your answer is one word: FATCA. That's it. It is that simple.
U.S. persons will have all their foreign accounts disclosed by FATCA by next year. You think the number of remaining undisclosed foreign accounts is under 5,000? I think it is closer to 50,000. You said you have one of these. If it is over $10,000 you probably know the penalty for not disclosing it can be $10,000. It can be less under present mitigation guidance, but it can be a lot more if it is a willful violation. Up to the IRS just taking the money in the account (yes, congress has given them the authority and they have written a penalty structure that actually allows this).
That is why FATCA is a BFD and why you are very very wrong thinking this is just some propaganda deflection by the IRS. I can assure you it is not. It is a cash cow for the IRS that still has a lot of milk left in it.
And none of the above is legal advice. It is just the ramblings of an uneducated individual throwing darts at the wall, FTR.
This post was edited on 6/5/14 at 3:11 pm
Posted on 6/5/14 at 5:18 pm to Tiger n Miami AU83
quote:Hundreds of thousands?
Since the IRS started going after these accounts, hundreds of thousands have been disclosed and billions in taxes and penalties paid.
From your link:
quote:Those are totals.
40,000 account holders have participated in the IRS program
Maybe the issue is definition.
In your numbers, are you counting US citizens working overseas, while maintaining a normal bank account there? Something on order of 7 million Americans work abroad in that case. So "Hundreds of Thousands" of >$50K accounts might apply. "Hundreds of Thousands" of fraudulent accounts? Different issue.
My presumption though was we were addressing US citizens living in the US while maintaining overseas accounts. That would be the IRS antenna raiser. Obviously a person who happens to be a US citizen residing, working, and paying taxes abroad is a wholly different issue.
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