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Here is an interesting article from AP about citizenship for sale in the Caribbean. Most nations sell citizenship, or at least permanent residence with a path to citizenship (including the U.S. and many EU nations) - Caribbean nations make it very affordable. We have helped our clients obtain citizenship in various countries, mostly in East Caribbean. The need for a second citizenship is usually fueled by tax planning (i.e., the client is planning to surrender primary citizenship) or politics (if you may need to flee Russia or Saudi Arabia someday, you need a second passport). Costs and difficulty of obtaining second citizenship varies by country, but in all cases the most important consideration is the ability to travel using the second passport. For example, an individual holding a U.S. or a Schengen passport may travel most anywhere in the world without a visa. The same is not true for citizens of many Caribbean nations.
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The Internal Revenue Service today reopened the offshore voluntary disclosure program to help people hiding offshore accounts get current with their taxes and announced the collection of more than $4.4 billion so far from the two previous international programs.
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The U.S. government is requesting information on American account holders from several more Swiss banks. These banks include the giant Credit Suisse, as well as HSBC, Julius Baer Group Ltd., Wegelin & Co., Basler Kantonalbank and Zuercher Kantonalbank. These banks are apparently under secret grand jury investigation in the U.S. The banks have not yet commented on the inquiry.
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According to a press release issued by the Internal Revenue Service, U.S. taxpayers with foreign bank accounts now have a second chance to come forward a plead mia culpa. The new program has a deadline of August 31, 2011. The taxpayers who come forward will be subject to penalties and interest on unpaid taxes for the past 8 years, and an additional penalty of 25% of the highest balance in the offshore account.
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A week after the upper house of the Swiss parliament voted to allow disclosure of UBS clients to the US government, the lower house of Switzerland’s parliament voted to prevent the disclosure of the names and financial secrets of as many as 4,450 Americans who held undeclared accounts at UBS.
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The quagmire involving US taxpayers with unreported foreign bank accounts continues. The latest word: IRS has over 200 dedicated agents conducting audits of those taxpayers who voluntarily disclosed them prior to the October 15, 2009 deadline. These agents are conducting full audits of the taxpayers who came forward (where there is smoke, there is fire, and potentially other unreported tax issues) and looking to impose fairly significant civil tax penalties. The audits also extend to those taxpayers who voluntarily came forward following the amnesty deadline, hoping to avoid criminal sanctions.
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On January 22, 2010 the Swiss Federal Administrative Court published its first judgment with respect to the IRS’s request for information. The case relates to a UBS client who failed to provide the bank with a Form W-9.
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As the October 15 deadline has come and gone, more and more of our clients have reported receiving letters from UBS.
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The Internal Revenue Service has extended the deadline to participate in the FBAR amnesty program to October 15, 2009, and has indicated that there will be no more extensions.
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The IRS has announced today that UBS will reveal names of 4,450 American account holders. The actual names have not yet been released, and over the next few months these account holders will receive notices from UBS that their names will be disclosed to the IRS. The account holders will then have the option of appealing the proposed disclosure to the Swiss appellate court on the grounds that the disclosure would violate Swiss banking secrecy laws. It is not yet clear how successful such appeals may be.
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Earlier this summer, the Ninth Circuit Court of Appeals released an opinion that sheds some light on the level of protection granted by the California exemption for private retirement plans.
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Several years ago the Justice Department subpoenaed names of Americans who had Visa and MasterCard accounts with offshore banks. The IRS then offered these taxpayers a choice, come forward voluntarily and we will waive criminal prosecution and some monetary penalties, or wait until we get to you and then take the risk of criminal penalties.
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Last week I travelled to Zurich to meet with several Swiss private banks. We do a lot of business with Swiss banks, and the past few months have brought about many changes.
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The UBS scandal may have had a more profound impact on asset protection planning than previously suspected.
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Following the indictment of several UBS AG (Switzerland) employees, the Justice Department requested permission from federal court to have the Internal Revenue Service issue John Doe summons to UBS AG (the Swiss parent of UBS). The John Doe summons will instruct the Swiss bank to provide to the IRS information on all U.S. taxpayer who may have bank accounts with the bank in Switzerland.
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The big tax news this month was the Justice Department’s loss in the Wesley Snipes case. Snipes has been cleared of federal tax-fraud and conspiracy charges, but was convicted on three misdemeanor counts of failing to file a tax return. He now faces up-to three years in a prison for the misdemeanor convictions.
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