William Byrnes' Tax, Wealth, and Risk Intelligence

William Byrnes (Texas A&M) tax & compliance articles

One Response to “Voluntary Disclosure for Offshore Accounts is Back”

  1. The 5% penalty applies to accounts that were neither established by the taxpayer nor controlled by the tax payer. There are four criteria that must be met. The tax payer: (1) did not open or cause the account to be opened; (2) has exercised minimal, infrequent contact with the account; (3) has not withdrawn more than $1K from the account in any year during the look back period (unless the withdrawal was to move the account to the U.S.); and (4) can establish that all applicable U.S. taxes have been paid on
    funds deposited to the account.


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