#fatca voluntary disclosure | Explore Tumblr Posts and Blogs

clockmetal5 · 2 years

Text

Fbar Voluntary Disclosure Penalty Calculations Explained

Our attorneys work directly with our clients to identify potential tax issues and develop plans to ensure that their foreign assets are in full compliance with FATCA and other offshore account reporting requirements. The Internal Revenue Service has had success encouraging taxpayers with offshore accounts to disclose their foreign accounts and pay back taxes. In 2009 and 2011, the IRS announced the Offshore Voluntary Disclosure Program which allowed taxpayers to come forward and report foreign income, bank accounts, and other assets. foreign tax credit corporations The IRS had 33,000 voluntary disclosures, resulting in $4.4 billion in taxes, interest and penalties. In 2012, the IRS reopened the OVDP and set no deadline for the program to end. Not a single one of Andrew’s clients’ Streamlined Domestic Offshore or Streamlined Foreign Offshore filings have ever been challenged or rejected by the IRS. With the help of The Law Offices of Andrew L. Jones, you can discover whether you’ve committed a Foreign Bank Account Report (FBAR, also known as FinCEN Form 114, and formerly Form TD F 90-22.1) violation. if you reside in a country which has a tax treaty with the US, like Canada, you can claim a reduced rate of withholding tax to be deducted from a payment. You’re listening to another episode of PwC’s Tax Tracks at/ca/taxtracks. This series looks at the most pressing technical and management issues affecting today’s busiest tax directors. Through interviews with prominent PwC tax subject matter professionals, Tax Tracks is an audio podcast series that is designed to bring succinct commentary on tax technical, policy and administrative issues that provides busy tax directors information they require. The streamline disclosure program offers a chance for those who have committed non-willful violations of tax law by failing to report taxable foreign income-generating assets or bank / financial accounts, or other required foreign information reporting a chance to be brought back into compliance. However, the keyword regarding this program is “non-willful.” You must submit a certified statement that you did not willfully fail to disclose this information to avoid paying income taxes. If you are found to have falsely certified non-willfulness, severe criminal and civil penalties can occur. The IRS is now fully committed efforts to finding and prosecuting non-compliant U.S. taxpayers with undisclosed foreign source income and offshore accounts. The Bank Secrecy Act and the Foreign Account Tax Compliance Act require both foreign financial institutions and U.S. taxpayers to disclose the non-U.S. Compliance failures can result in both civil and criminal penalties and interest charges. The IRS reports that its programs have gathered approximately $11 billion in delinquent tax, penalties, and interest, and more than 1,500 indictments in recent years. Our FBAR and FATCA compliance team understands the complex challenges you face with foreign asset reporting regulations, the IRS voluntary disclosure program, and the disclosure and withholding requirements imposed on foreign financial institutions. If you are one of the many U.S. residents who own overseas assets and were not aware of the disclosure requirements for these accounts, you should consider disclosing your offshore assets and becoming tax compliant without delay. A person who is required to file Form 114 and fails to do so may be subject to a penalty not to exceed $10,000 per violation. A person who wilfully fails to file or report an account may be subject to a penalty equal to the greater of $100,000 or 50 percent of the balance in the account. Just because these assets are in a foreign country, however, this does not mean that they are not subject to taxation or foreign information reporting by the IRS. In fact, over the last decade, the IRS has cracked down on those who fail to report foreign accounts, fail to file required foreign information returns, and evade income tax from taxable offshore income-generating assets on their returns, which can lead to severe civil and criminal penalties. As if the very real possibility of penalty increases does not give taxpayers who have undisclosed foreign accounts, a reason to participate in the disclosure program as soon as possible, maybe the possibility that they will be disqualified tomorrow will. Though the provisions of agreements with foreign banks related to the FATCA legislation, an electronic data exchange protocol has been established and is now in full effect. It means that a foreign bank can send the IRS all of your foreign account information in a matter of a few seconds electronically. Understand your clients’ strategies and the most pressing issues they are facing. The United States has recently enacted legislation commonly referred to as FATCA for the specific purpose of finding U.S. taxpayers who have unreported foreign accounts and income. FATCA requires foreign banks and financial institutions to report accounts held by U.S. taxpayer clients. FATCA and increased enforcement of civil and criminal penalties for unfiled Foreign Bank and Financial Account Reports , have given the IRS powerful new weapons in their search for undisclosed foreign assets and accounts. The penalties is $10,000, per return with an additional $10,000 added for each month the failure continues beginning 90 days after the taxpayer is notified of the delinquency, up to a maximum of $50,000 per return. In the mid-2000s, the IRS began aggressively pursuing foreign financial institutions for information concerning deposits held by those institutions on behalf of U.S. taxpayers. That effort has resulted in an unprecedented period of world-wide intra-governmental cooperation to identify unreported accounts and untaxed income. If you have, we can solve it quickly and for the least possible cost. We are available by phone nationwide or by appointment at your choice of 6 different offices throughout California. We took over a case from a small firm that unsuccessfully submitted multiple clients to IRS Offshore Disclosure. Our lead attorney is one of less than 350 Attorneys to earn the Certified Tax Law Specialist credential. PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. With very limited exceptions for individuals born with diplomatic agent level immunity, all persons born in the United States acquire U.S. citizenship at birth as a matter of U.S. law and without regard to intent. or other 3 letter government faction for criminal investigation and possible prosecution. If you are seeking FBAR Amnesty 2015 or prior year FBAR non-compliance, you can use this article to assist you with getting into compliance for 2019 and prior years. If you are seeking FBAR Amnesty 2016 for prior year FBAR non-compliance, you can use this article to assist you with getting into compliance for 2019 and prior years. If you are seeking FBAR Amnesty 2017 for prior year FBAR non-compliance, you can use this article to assist you with getting into compliance for 2019 and prior years. New information-sharing agreements between the United States, foreign governments, and foreign financial institutions are closing the door on bank secrecy and are exposing non-compliant taxpayers who hold undisclosed assets abroad. The IRS’s Offshore Voluntary Disclosure Program offers a path for U.S. tax residents to become compliant with their outstanding filing obligations while mitigating or minimizing the penalties associated with non-compliance — however, this program can close at any time. Alternatively, the IRS could choose to limit the types of taxpayers who may enter into the streamlined program, or increase the penalties offered within the framework. Once the program closes, taxpayers may once again face full audits and investigations, full FBAR penalties, and potential prosecution. Depending on the aggregate amount of a taxpayer’s offshore assets, penalties could reach as high as 50% of the value of each overseas account per year. Finally, with the implementation of the Foreign Account Tax Compliance Act and the IRS's increased focus on offshore tax evasion, U.S. taxpayers are increasingly unable to avoid their obligation to report their accounts and income worldwide. Each year, thousands of Americans utilize foreign bank or financial accounts and employ foreign income-generating assets. In order to avoid being disqualified from the program, it is in your best interest to contact an experienced tax attorney to find proper representation to your undisclosed foreign accounts as soon as possible. The legal team at Thorn Law Group is well positioned to advise clients on complex tax issues associated with their offshore accounts and other foreign financial assets. The below video explains the NEW streamlined Offshore Voluntary Program. I offer aFREEIRS OVDP check-up and aFREEin-depth financial consultation. I guarantee that after your consultation you will feel comfortable knowing how I, as an experienced professional in the industry, will resolve your case. Because of the changed amensty programs, many individuals now have an easier path to get compliant. The Offshore Voluntary Disclosure Program began in a slightly different form and with a slightly different name in 2009. It was on an offshoot of the traditional domestic voluntary disclosure program, which has been on the books for many years, focused on FBAR violations in particular. Under this program, taxpayers who had failed to report foreign bank and financial accounts or other foreign assets on their returns could be brought back into compliance and avoid criminal liability and the most severe civil penalties. The terms of the current 2012 voluntary disclosure program may be unappealing to many taxpayers. Our attorneys are very familiar with the reporting requirements individual taxpayers must meet under FATCA and other U.S. tax laws and regulations. We make certain that our clients understand their legal obligations and are taking appropriate steps to bring their offshore accounts and assets into full compliance with the law. Our tax law firm also assists foreign financial institutions with IRS reporting requirements and works with FFIs to design effective FATCA compliance strategies and programs. The Form 114 is an annual report that must be filed independent of a taxpayer’s tax return on or before June 30 of every year. The monetary penalty can lead to inequitable results for many taxpayers, especially given the market fluctuations since 2008. The IRS appears to recognize that the voluntary disclosure programs many not be appropriate for all taxpayers. how to fill form 3520 For example, certain non-resident taxpayers as well as dual citizens may be allowed to correct their prior income and reporting delinquencies without entering a voluntary disclosure program. We will happily offer you a FREE initial consultation to determine how we can best serve you. The two amnesty programs to come clean with the US government are the traditional OVDP or the Streamlined Offshore Program. If you are seeking FBAR Amnesty 2018 for prior year FBAR non-compliance, you can use this article to assist you with getting into compliance for 2019 and prior years. We're proud to celebrate over 30 years working with international expat communities around the world. Through all the changes we've seen as our world evolves, our core value to serve our clients wherever they are, remains the same. In addition to tax and interest, the IRS generally requires taxpayers to pay a monetary penalty equal to 27.5 percent of the highest aggregate balance of the taxpayers' foreign bank accounts/entities or value of foreign assets during the period covered by the voluntary disclosure. Despite the severity of the monetary penalty, taxpayers should consider the risk of criminal prosecution for non-compliance with the foreign account reporting rules and the potential for criminal penalties. The rationale seems to be that if a person resides outside of the United States for 11 out of 12 months in a year, the IRS will cut them a break as tax filing. You are entering the program “voluntarily,” which means you are not currently under audit or examination. People who are both Willful and Non-Willful may enter the program, but non-willful individuals typically only submit to OVDP under specific scenarios (MTM Elections, Opt-Out). Each week, the Treasury Department announces a new agreement with a foreign country on FATCA cooperation. Just last week, the Swiss government and the United States announced such an agreement. More than 30,000 voluntary disclosures have been made since the programs began in 2009, resulting in more than $5 billion in back taxes, interest and penalties paid to the IRS. The voluntary disclosure program provides many benefits for certain taxpayers. Most importantly, taxpayers can avoid potential criminal prosecution for failure to report their foreign accounts. In addition, taxpayers can resolve their delinquent tax and reporting issues in a relatively streamlined process. While we have come across clients who have willfully omitted foreign accounts and income from their U.S. tax returns, most clients that contact us for offshore compliance issues have recently realized that they have foreign income and information reporting requirements . They’ve never been on the wrong side of the law and have never had the need to hire an attorney. They are terrified of the massive civil penalties that can be assessed for noncompliance, even for non-willful violations. Since 2009, the IRS has allowed taxpayers with undisclosed foreign accounts and unreported foreign earnings to enter voluntary programs to correct these compliance failures. Under the terms of these programs, taxpayers typically submit eight years of amended tax returns, Forms TD F 90-22.1 ("FBARs") reporting the foreign accounts, and account statements of their foreign accounts. Financial institutions and host country tax authorities can transmit and exchange FATCA data with the United States. Search and download a monthly list of approved foreign institutions that have a Global Intermediary Identification Number . This website uses cookies so that we can provide you with the best user experience possible. Cookie information is stored in your browser and performs functions such as recognising you when you return to our website and helping our team to understand which sections of the website you find most interesting and useful. The streamlined procedures are designed to provide to taxpayers in such situations with a streamlined procedure for filing amended or delinquent returns and resolving their tax and penalty obligations. Beginning with the 2011 tax year, a penalty for failing to file Form 8938 reporting the taxpayer’s interest in certain foreign financial assets, including financial accounts, certain foreign securities ,etc. Beginning September 1, 2012, such taxpayers, provided they are deemed not to be compliance risks, may simply submit delinquent tax returns for the past three years, FBARs for the past six years, and certain other information without being subject to a civil or criminal penalty. This special dispensation may be particularly helpful for long-time residents of Canada or other nations who remain U.S. taxpayers. OVDP is designed to provide to taxpayers with such exposure protection from criminal liability and terms for resolving their civil tax and penalty obligations. U.S. citizens must file U.S. tax returns and report and pay tax on their worldwide income. Subject to certain de minimis exceptions, if a U.S. citizen is a resident or citizen of Israel, he or she must file a U.S. income tax return and report his or her worldwide income to the IRS. The Form 114 is an annual report that must be filed independent of a taxpayer's tax return on or before June 30 of every year. In addition, taxpayers must pay tax on the previously unreported income, interest, and certain penalties. Specifically, US taxpayers are required to comply with FATCA by properly disclosing and reporting their foreign accounts and foreign income in their Tax Return filings and FBAR reporting requirements of foreign and offshore accounts. In order to ensure the taxpayer has complied, the foreign financial institution issues a FATCA Letter, which will usually be accompanied by two forms – a W-9 and a W-8 BEN. Only US taxpayers are required to complete a W-9 and return the completed W-9 form to the foreign financial institution. As former IRS lawyers, our legal team has an extensive understanding of the U.S. tax laws and regulations governing foreign accounts and other financial assets held outside of the country. We know how the IRS and other federal authorities examine and investigate unreported offshore assets and accounts. PricewaterhouseCoopers refers to PricewaterhouseCoopers LLP, an Ontario limited liability partnership, or, as the context requires, the PricewaterhouseCoopers global network or other member firms of the network, each of which is a separate and independent legal entity. You have 30 days to inform your financial institution or a withholding agent of the change.

1 note · View note

stonewine99 · 2 years

Text

International Advisory Experts

Multinational corporations usually employ international tax specialists, a specialty among both lawyers and accountants, to decrease their worldwide tax liabilities. We’ve received best-in-class training in national IRS, tax attorney and CPA conferences. This keeps our firm on the leading edge of ever-changing tax laws and IRS Streamlined and Offshore Voluntary Disclosure audit procedures. Our multidisciplinary approach enables us to envision how tax factors operate within the context of our clients’ personal, financial and legal goals. We are also experts at designing frameworks around business strategies for recognizing cross-border tax planning opportunities. The demand for serious German and English speaking legal, tax and business consulting for companies and private clients has increased. Such systems of taxation vary widely, and there are no broad general rules. These variations create the potential for double taxation and no taxation . Income tax systems may impose tax on local income only or on worldwide income. Generally, where worldwide income is taxed, reductions of tax or foreign credits are provided for taxes paid to other jurisdictions. He advises on corporate, commercial, tax, intellectual property, regulatory, and product liability law. He provides tax support for clients’ cross-border transactions, including international tax planning and transfer pricing. He previously worked in the Shanghai office of the first French law firm established in Shanghai as well as a leading Chinese law firm. He has more than 18 years’ experience working extensively for mainly European clients. She has accumulated 24 years of experience in local and international taxation at Taxhouse, EY, and Andersen and industry experience in finance and accounting with Procter & Gamble. With our legal, transfer pricing, tax controversy, and indirect tax teams, we are superbly qualified to assist you with all aspects of your international taxation needs. The University of Melbourne’s Master of International Tax is available to both law and non-law graduates seeking global context for their tax law practice. Students learn how individuals and businesses manage foreign income, how tax systems operate in a global economy and the role of the OECD and the UN in managing bi-lateral tax treaties, among other subjects. Melbourne Law School’s Tax Group is home to international taxation research and hosts regular events. Whether you are part of a domestic or foreign business, we will help your business remain compliant with U.S. tax laws and any applicable international tax. Experienced legal counsel from an international tax attorney can help individuals working abroad or retiring overseas maintain their citizenship through fulfilling their tax obligations. International tax attorney David W. Klasing has extensive experience in international tax planning, offshore tax controversies, and foreign account compliance. At the Law Office of David W. Klasing, our tax professionals can assess an array of tax concerns related to double-taxation of expatriates, tax minimization, FBAR, FATCA, and other international tax problems. Our understanding of the interplay between domestic and international tax laws allows us mastery over the full tax consequences of our clients’ transactions. Visit the Tax Services area of our site to learn more about the many tax and regulatory consulting services we offer. When a U.S. taxpayer illegally places money in overseas accounts in an effort to avoid paying taxes that are due in the United States, he or she could be subject to civil and criminal tax penalties in the United States. The accumulated funds offshore often flow from offshore unreported inheritances, investments, real estates or business activity. Where foreign information reporting and income tax reporting is purposefully not complied with in order to illegally evade U.S. taxation, international tax evasion occurs. That’s where an international tax attorney is able to provide help by making sure you or your company are in compliance and are legally reducing worldwide taxation. PwC’s international tax professionals have the resources, experience and local competencies to help companies like yours address your cross-border needs. The attorney will give you the help you need to set up a smart and legal financial and business plan for your company that is expanding from the U.S. offshore, or seeking to do business in the U.S. from offshore. If you are a foreign national in the United States or a U.S. citizen living at home or abroad and you hold significant foreign assets in excess of $10,000 it is likely that you have foreign disclosure obligations. Even mere mistakes can be punished harshly, so it is essential to obtain experienced international tax planning and FBAR compliance services. At the Tax Law Offices of David W. Klasing, my legal team and I are committed to helping you remain compliant with U.S. and international tax laws. We will apply our understanding of international tax treaties to help you maintain your citizenship with minimal tax burdens. A new income tax law, passed in 1980 and effective 1981, determined only residence as the basis for taxation of worldwide income. However, since 2006 Mexico taxes based on citizenship in limited situations . The United States taxes the worldwide income of its nonresident citizens using the same tax rates as for residents. After living in Saudi Arabia, Korea, and Japan, Ted became aware first-hand of the challenges that complying with U.S. tax law can present when living abroad. Now that Ted has returned to Oregon, he devotes his practice providing tax services to expatriates in those countries and around the world. International taxation is the study or determination of tax on a person or business subject to the tax laws of different countries, or the international aspects of an individual country's tax laws as the case may be. "U.S. persons" abroad, like U.S. residents, are also subject to various reporting requirements regarding foreign finances, such as FBAR, FATCA, and IRS forms 3520, 5471, 8621 and 8938. The penalties for failure to file these forms on time are often much higher than the penalties for not paying the tax itself. Moving your tax offshore and leveraging international tax structures is a serious financial decision, and should not be taken lightly. Done wrong, it can have serious consequences both legally and financially. If you are looking to live abroad or operate a business overseas or bring a foreign company to the United States, obtaining experienced international legal counsel is the first step to a prudent approach. The Orange County and Los Angeles-based international tax lawyers at The Law Offices of David W. Klasing are committed to helping you avoid any unnecessary domestic or foreign tax burdens. We are also proud to assist expats, tax residents, non-residents, and businesses in maintaining all tax reporting and payment obligations. An international taxation attorney can provide the advice you need to protect as much of your income as possible, whether you’re operating as an individual or as a company. form 3520 instructions For individuals, one common type of international taxation involves personal income tax for both citizens and foreigners who earn money inside the country. Some countries even will tax money its citizens earn in foreign countries. As international taxation laws are complex by nature, trying to keep all of the information straight from country to country can be challenging. We help clients develop and implement integrated lifetime and testamentary plans. We help clients capture the full value expected from every transaction. 2019 IRS TAX RESOURCES - Download almost all IRS resources you may need to answer your tax questions. And remember as a CPA firm we can also prepare the returns, forms, and amended returns to solve your tax problem. IRS REINSTATES VOLUNTARY OFFSHORE DISCLOSURE PROGRAM FOR THOSE WHO HAVE NOT FILED THEIR FOREIGN TAX REPORTING FORMS You can avoid criminal penalties and possible secure reduced tax penalties. For example, the U.S. imposes two levels of tax on foreign individuals or foreign corporations who own a U.S. corporation. First, the U.S. corporation is subject to the regular income tax on its profits, then subject to an additional 30% tax on the dividends paid to foreign shareholders . For example, most countries tax partners of a partnership, rather than the partnership itself, on income of the partnership. A common feature of income taxation is imposition of a levy on certain enterprises in certain forms followed by an additional levy on owners of the enterprise upon distribution of such income. Working with multinationals and large local firms, she has provided structuring and transactional direct and indirect tax advice on the full range of corporate tax activities. She is a key member of the advisory team to the Romanian Ministry of Finance with regard to the introduction and amendment of the Fiscal Code. A jurisdiction relying on financial statement income tends to place reliance on the judgment of local accountants for determinations of income under locally accepted accounting principles. Often such jurisdictions have a requirement that financial statements be audited by registered accountants who must opine thereon. The foreign corporation will be subject to U.S. income tax on its effectively connected income, and will also be subject to the branch profits tax on any of its profits not reinvested in the U.S. Thus, many countries tax corporations under company tax rules and tax individual shareholders upon corporate distributions. Various countries have tried attempts at partial or full "integration" of the enterprise and owner taxation. Where a two level system is present but allows for fiscal transparency of some entities, definitional issues become very important. Vietnam used to tax its citizens in the same manner as residents, on worldwide income. My Los Angeles international tax law team and I understand the tax treaties the United States has with several other countries. We will apply our taxation knowledge to protect your business from double taxation. programs will address the tax systems of various countries, as well as the various ways that tax law applies across borders. They will also typically cover some aspects of treaty law and other issues that transcend borders. I’m a Certified Public Accountant with 30 years diversified business experience operating as your Certified Public Accountant with a specialty in international taxation preparation and planning. That is why compliance with all the relevant tax laws is critically important. We are experts in tax and tax laws and will ensure that everything is above board and 100% tax compliant. At Point Square Consulting we offer top quality international tax consulting and offshore IRS representation services to individuals and businesses. We serve clients with wide ranging cross-border tax and business needs from tax return preparation to international tax planning to IRS tax dispute resolution. We are part of an extensive network of expert international tax consultants around the world and we can walk you through the entire process of U.S. inbound or outbound tax planning. Governments usually limit the scope of their income taxation in some manner territorially or provide for offsets to taxation relating to extraterritorial income. The manner of limitation generally takes the form of a territorial, residence-based, or exclusionary system. Some governments have attempted to mitigate the differing limitations of each of these three broad systems by enacting a hybrid system with characteristics of two or more. The international taxation laws for corporations vary quite a bit from country to country, leading to complexity. Tax rates can also vary quite a bit for business owners operating in multiple countries. Igor has over 10 years’ experience working as a tax and legal consultant. He has extensive experience in tax advisory services, including international taxation, value-added tax, customs, corporate income tax, tax dispute services, and personal income tax. He co-authors the Serbia and the Montenegro chapters for the Bloomberg Tax VAT Navigator. That’s where an experienced international tax attorney can provide an invaluable service. To schedule an initial, reduced-rate consultation call us at or online today. When you entrust the Tax Law Offices of David W. Klasing with your tax strategy needs, you gain the benefit of an experienced international tax lawyer and a seasoned CPA for the price of one. Prior to becoming a tax attorney, Mr. Klasing worked for nine years as an auditor in public accounting. After gaining a master’s degree in taxation, he became a Certified Public Accountant . Nicolas is responsible for CMS’s China Tax Practice Area Group and Lifesciences and Healthcare Sector Group. We listen to You and we always aim to understand Your needs.Transparency Absolute transparency of our services! Starting your career at MBAF is a great opportunity to gain valuable experience. We understand the unique accounting needs of the Automotive Industry. We work with hundreds of clients in every aspect of the real estate industry. The country passed a personal income tax law in 2007, effective 2009, removing citizenship as a criterion to determine residence. Mexico used to tax its citizens in the same manner as residents, on worldwide income. Some jurisdictions extend the audit requirements to include opining on such tax issues as transfer pricing. Jurisdictions not relying on financial statement income must attempt to define principles of income and expense recognition, asset cost recovery, matching, and other concepts within the tax law. Some jurisdictions following this approach also require business taxpayers to provide a reconciliation of financial statement and taxable incomes. Many systems allow for fiscal transparency of certain forms of enterprise.

1 note · View note

decaffeinatedtragedysalad-blog1 · 3 years

Text

Why set up offshore company in Singapore - Case 1

The following study is about a qualified professional in Australia who is interested in restructuring his international real estate investments. Ian Brown is a mining engineer in a high demanding career. His family is familiar with real estate investment, and he knows that going offshore can enhance his portfolio. What are the best options for him when it comes to international real estate holding?About the clientLife Stage: Late 30’s ProfessionalEmployment Status: Employed in the Mining industryHousehold Income Range: $100K‐ $200KAsset Summary: 5 properties approx $2mil

Lives in Perth, Australia

Married

2 Children

Ian Brown, a high-net-worth individual in his late 30s living in Perth, has decided to invest a significant amount of his wealth in real estate. Mr Brown has worked his way up the corporate ladder in Australia. His wife is a teacher at a private school in Perth while his 2 children attend the same school. The family has made smart investing choices, purchasing many local properties that produced enough income to allow Mr Brown and his family to live comfortably.At an early age, Mr Brown grew fond of helping others. When entering college, he believed he was going to move into med school to become a doctor, as his mother has been pushing him to do so, but soon realized that he wanted to help others on a larger scale. He realised that if he goes into the engineering field, he could help creating a livelihood for others through operating of processing plants. He was near the top of his class and landed a great job right out of college.The job he landed was in Perth, a place that he always dreamed about living in because of the weather and the friendly people. Mining was a boom at that time and is an industry in demand for talents, so when he landed a high paying job right out of college, he wanted to ensure that he used his income in a way that would protect him for the future. He knew that investing in real estate early is the key to unlock a comfortable future.As a reward for Mr Brown landing his dream career and getting engaged to his childhood sweetheart, his parents lent him the money to purchase his first property, a small home he rented to a local family in Perth. Since then, he has invested in many more properties, creating a healthy portfolio.Now, Mr Brown is beginning to think about his long-term future. He has always wanted to have something substantial for his children, and he wants to be able to put them through college the same way his parents did for him and his sister. He understands that these investments will play an essential role in achieving that goal and will even play a massive part in a retirement plan. He has not thought about what he wants to do precisely but has considered moving back to Melbourne to be close to his parents.His family achieved local success and only invested in domestic properties, but Mr Brown wanted to branch out and invest in other assets internationally. He is thinking of investing in options and futures on the Nasdaq, as well as shares in technology companies in South East Asian countries.Mr Brown wants to arrange his return on investment in a tax-efficient manner. He is also considering tax efficiency when it comes to selling his non real-estate assets. While his family has been a great help in the investment process, they are not familiar with other asset classes, and also not familiar with the best ways to stay tax efficient while investing offshore.Mr Brown is not engaged in developing real estate, the current nature of his income is rental income or, in the case of a sale, a capital gain. In many countries, this is considered “passive income” for tax purposes.He is interested in forming an offshore company to receive profits gained from investing in options and futures and sales of shares in technology companies, but does not know in which country to create the entity or what the preferred structure.His needsGiven Mr Brown's current situation, there are many services of which he can take advantage to alleviate some of his pressures. With the proper guidance, he can grow his range in which he purchases securities, as well as benefit from holding shares of technology companies in an investment holding company, and remain compliant.Mr Brown has surplus funds to invest in securities and potential high-returns of technology companies, and has created an excellent base for his success, but with skilled advisors, he can create a one-of-a-kind plan to take his wealth to the next level.Offshore investments in shares and securitiesWith his investments in offshore securities, Mr Brown is taking advantage of thriving markets from all around the world.The biggest draw to international real estate is probably the diversification that comes with investing in foreign markets. Diversification is a pillar to any healthy portfolio. Modern Portfolio Theory, an investment technique used by individuals around the world, emphasises that investing in more than one class of investments will ensure that your portfolio is not too concentrated, protecting you from market failure.When Mr Brown decides to not just invest in Australian properties and find offshore assets, he is protecting himself from the possibility that the real estate market in a single country may begin to perform poorly. This would mean his hard work could be for nothing.Further, many individuals that choose to invest in international securities often move onto other international opportunities. Foreign ownership in securities on the Nasdaq is a “gateway investment” of sorts.Some investments in shares of technology companies can lead to residency in a new country which is advantageous for reasons ranging from a new retirement location to tax optimisation. This is attractive for those looking to expatriate or those who want to qualify for a long-term visa in order to live in a different country. If retiring abroad is on your retirement plan, this can play a significant role in meeting this goal.It is interesting to note that Mr Brown’s potential investment in a technology company in Singapore, may qualified him for an Employment Pass or even a Permanent Resident, via the Singapore Global Investor Programme.There are many tax benefits that Mr Brown can take advantage of, as well, especially when he finds the right structure in which to hold his investments.Further, for those worried about holding the entirety of their wealth in a single place, offshore holding companies allows them to place fractions of their assets in a new country, which can protect them in some circumstances, such as a lawsuit. Again, all of this is enhanced when an individual chooses to form an offshore company.Offshore company formationThere are countless benefits to keeping investments in offshore accounts or holding company. Let us take a look at what Eleanor can be taken advantage of when holding her assets in an offshore company.Tax BenefitsThere are a plethora of tax benefits for going offshore, whether it’s expatriating and living entirely in a new country, working, investing, or banking. In many cases, you can lower your tax responsibilities while staying legally compliant. I must emphasise here that an individual still must file earnings with the country that they are a resident of. An offshore company does not allow you to hide income.Asset ProtectionAlthough you can’t completely dodge the tax burdens of your home country with an offshore entity, you can enjoy an amount of asset protection. Because the funds are held offshore in a bank, they are not as easily accessible during a frivolous lawsuit. An offshore company can protect you from creditors with certainty.Also, to sue an offshore business, many courts require a separate lawsuit in the foreign jurisdiction. This means that if someone is trying to get your money, they must also sue your offshore company. The new suit will not consider the original lawsuit. With this, many avoid the suit entirely.Minimize ProbateWhen an individual passes away, their living heirs can be taken care of with your offshore investment, but they will have to deal with probate, a tax that occurs when an investment is passed on after a person dies. The probate can be eliminated when the offshore company is used to make the investment.Tax complianceMany are feeling confined because of local tax structures. Others have wealth but no form of asset protection. By creating an offshore company, an individual can do both and more. Companies allow you to hold funds, make investments, and so much more. The best part is that it is entirely legal.Many tax questions arise when creating an offshore company. The average investor, even the most financially savvy, is not entirely knowledgeable of tax laws in every single country. Eleanor is one of these individuals. She is a smart individual but needs additional assistance to not only ensure she is saving the most she can on taxes through smart investing but also that her tax efficiency is legal.If any of these apply to you, consider taking part in a tax compliance check-up. It would never hurt to make sure you are in the clear when it comes to your taxes. If you live in Australia, you have to consider government hurdles like the Foreign Account Tax Compliance Act (FATCA). Other countries have their policies concerning foreign earned or held income. It’s a lot to remember.kimbocorp offers the opportunity for individuals to review, together with a tax attorney, the compliance of their past year’s individual or corporate tax returns. The review is conducted on a no-name basis and in complete confidentiality. Should there be a need to amend any previously filed tax returns, we will guide you through the various voluntary disclosure programs that are available to investors in most developed countries.About kimbocorpkimbocorp is registered corporate services provider with the Accounting Corporate Regulatory Authority (ACRA). Together with our partner

Singapore banks,

our company can now offer the full investment holding company set up to Australian clients, both residents, and non-residents.Building on many years of experience in corporate advisory in Singapore, kimbocorp provides corporate advisory services to Australian individuals and corporates. The Singapore corporate system is highly regarded around the world, well known for being transparent, secure, non-biased and sophisticated. Choosing Singapore as a holding company destination is selecting years and years of financial stability and growth.The advantages of having an offshore holding company in Singapore include currency and investment diversification, asset protection, and the possibility to deposit assets in some of the most innovative, secure, highly-recognised, best-capitalised banks in the world.

#kimbocorp #startup #start #business #open company #company #singapore #usa #news

0 notes

dreamilycrazybird · 6 years

Text

#LasVegas international #tax #lawyers discusses International #TaxAttorney #Edina | Per Se #Corporations http://ow.ly/q5W730jrACb

Part VII of the French-American Chamber of Commerce Presentation by international tax attorney Eugene Sherayzen of Sherayzen Law Office, Ltd. This part discusses the concept of "per se"corporations. For more information about Sherayzen law Office visit http://sherayzenlaw.com Sherayzen Law Office, PLLC specializes in offshore voluntary disclosures (OVDP, Streamlined Compliance Procedures, etc.) and international tax compliance (FBAR, FATCA, Form 8938, foreign business ownership, foreign trusts, et cetera).

#law #lawyers #taxlaw #TaxLawAttorney #tax

2 notes · View notes

vincentvelour · 5 years

Text

If you’re a U.S. taxpayer with a foreign bank account, you need to know about FBAR

8/7/2019

By Palak Patel, Associate US Tax

In today’s global economy, it’s common for U.S. citizens to have income derived outside the U.S., along with bank accounts located in other countries. Most people in this situation understand that they’ll be taxed by the IRS on their worldwide incomes. But many are unaware they must also report foreign bank account information in certain situations. Failure to do so can have life-changing consequences.

The IRS tracks foreign assets held by U.S. taxpayers in a number of ways, primarily through supplements that must be completed and filed with federal tax returns. There is, however, one very important form that must be filed separately: the Report of Foreign Bank and Financial Accounts, or FBAR. The FBAR form must be filed with the Financial Crimes and Enforcement Network (FinCEN) each year. Its purpose is to provide foreign account information to the U.S. Treasury, which uses the data to track illicit funds and prevent the hiding of offshore assets.

The FBAR reporting threshold is fairly low. The form must be filed when the aggregate value of all foreign accounts exceeds $10,000 at any point during the year. Failure to file can result in severe penalties, with fines as high as $100,000 or 50% of the account balance, whichever is greater. This is one of the most expensive mistakes an expat can make, and yet many U.S. citizens with financial assets outside the country are unaware of FBAR’s existence.

Who must file

According to the IRS, any United States person, including a citizen, resident, corporation, partnership, Limited Liability Company, trust and estate, must file an FBAR if they have financial interest in or signature authority over at least one financial account located outside the U.S. It’s important to note that FBAR filing obligations don’t just apply to personal accounts. An employee or officer of a company or non-profit organization who has a signature authority over a foreign financial account must in certain situations file an FBAR, even if he or she has no financial interest in that account.

The reporting threshold is triggered when the total value of all foreign accounts exceeds $10,000 at any time during the year. This applies to all U.S. persons, regardless of age or circumstance.

The IRS defines a foreign financial account as any financial account located abroad, even if it doesn’t produce taxable income. There are five types of accounts that are exempt from FBAR reporting requirements:

U.S. government entity accounts

International financial institution accounts

U.S. military banking facility accounts

Correspondent or nostro accounts

Certain custodial or omnibus accounts

Further exemptions include:

IRA owners and beneficiaries

Participants in and beneficiaries of a tax-qualified retirement plan

Certain trust beneficiaries

U.S. entities included in a consolidated FBAR

How and when to file

FBAR is an annual report due on April 15. If you fail to meet the due date, you’re allowed an automatic extension to October 15.

As mentioned above, FBARs are not filed through the IRS with your federal tax returns. Instead, they must be filed electronically through the Financial Crime Enforcement Network’s e-filing system.

Any taxpayer who files an FBAR should keep records for each account reported. The records should be kept for five years from the FBAR’s due date and should contain the following information:

Name on account

Account number

Name and address of the foreign bank

Type of account

Maximum value during the year

Penalties

FBAR penalties depend on whether the failure to disclose is wilful or non-wilful. For those whose lack of filing is non-wilful, meaning they truly didn’t know about the reporting obligation, the fine can be as much as $10,000 per violation. If failure to file is intentional, it’s classified as a wilful violation and can result in a fine as high as $100,000 or 50% of the account balance at the time of the violation, whichever is greater. The maximum penalty for a violation under the Bank Secrecy Act is adjusted for inflation annually.

Filing delinquent FBARs

In an effort to encourage taxpayers with offshore assets to come forward and comply with FBAR requirements, the federal government has put several offshore voluntary disclosure programs in place. These programs allow non-complying individuals to voluntarily report undisclosed income as long as they are able to truthfully certify that their failure to report was not wilful avoidance. More information on these programs can be found here.

FBAR is not FATCA

FBAR should not be mistaken for reporting requirements that fall under the Foreign Account Tax Compliance Act, or FATCA. FATCA is part of the Hiring Incentives to Restore Employment (HIRE) Act, which was designed to promote transparency in the global financial services sector and enforce stricter tax compliance among taxpayers with financial assets outside the U.S. According to FATCA, any U.S. taxpayer with foreign account holdings that exceed an aggregate value of $50,000 on the last day of the tax year, or more than $75,000 at any time during the tax year, must report this information in their annual tax returns with Form 8398. In these circumstances, a taxpayer may be required to submit both an FBAR and a Form 8398.

Join thousands of global business leaders who receive weekly international expansion updates and need-to-know global information.

<![CDATA[// ><!]]>

0 notes

irsattrnytax · 6 years

Text

International Tax Reform December 2018 Updates FATCA - TTFI - GILTI

Tax Reform 1.0, aka the Tax Cuts and Jobs Act of 2017 has some very unpleasant surprises for those with income and assets overseas. The good news is there is a stand alone bi-partisan legislation that will be presented for Congress to vote on and for President Trump to sign into law that will allow Americans living overseas to "opt-out" of the US tax code by simply filing a certificate that they are in compliance foe the past three years and now live outside the US. If this is passed into law, the burdens of compliance for the US exapt will be greatly reduced. In this video, Advocate for Americans Overseas, Keith Redmond and Attorney John Richardson of citizenshipsolutions.ca join tax attorney Anthony E. Parent as they discuss the proposed laws, regulations and potential law suit that could greatly help those frustrated by a tax regime that seems rather out of control. In particular the three discuss - An end to Citizenship-Based taxation and replacing it with a true territorial tax system - Potential relief for The Transition Tax (Section 965) and Global Intangible Low Tax Income (GILTI) along with the Foreign Account Tax Compliance Act (FATCA). - The IRS's offshore disclosure program for those with criminal exposure. While the acronym has stayed the same as OVDP, it now stands for Offshore Voluntary Disclosure Practice instead he prior Offshore Voluntary Disclosure Program. The three agree that very few expats should ever be scared into an OVDP and if a disclosure program is needed, a Streamlined Disclosure is far for preferential. Ultimately what is needed right now from everyone concerned is unity. No matter your political affilication, the law needs to be changed. The law fails to raise revenue effectively and it is just morally wrong to tax people who are tax residents of outher countries. It is essential that everyone contact Congress and makes their voices be heard: Territorial Tax for Individuals must pass! Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 [email protected] https://youtu.be/y9J_stB9OWE IRS Medic

#IRS Medic

0 notes

taxattrny · 6 years

Text

International Tax Reform December 2018 Updates FATCA - TTFI - GILTI

#IRS Medic

0 notes

attrnytax · 6 years

Text

International Tax Reform December 2018 Updates FATCA - TTFI - GILTI

MORE HERE: https://ift.tt/2G7uT3T Tax Reform 1.0, aka the Tax Cuts and Jobs Act of 2017 has some very unpleasant surprises for those with income and assets overseas. The good news is there is a stand alone bi-partisan legislation that will be presented for Congress to vote on and for President Trump to sign into law that will allow Americans living overseas to "opt-out" of the US tax code by simply filing a certificate that they are in compliance foe the past three years and now live outside the US. If this is passed into law, the burdens of compliance for the US exapt will be greatly reduced. In this video, Advocate for Americans Overseas, Keith Redmond and Attorney John Richardson of citizenshipsolutions.ca join tax attorney Anthony E. Parent as they discuss the proposed laws, regulations and potential law suit that could greatly help those frustrated by a tax regime that seems rather out of control. In particular the three discuss - An end to Citizenship-Based taxation and replacing it with a true territorial tax system - Potential relief for The Transition Tax (Section 965) and Global Intangible Low Tax Income (GILTI) along with the Foreign Account Tax Compliance Act (FATCA). - The IRS's offshore disclosure program for those with criminal exposure. While the acronym has stayed the same as OVDP, it now stands for Offshore Voluntary Disclosure Practice instead he prior Offshore Voluntary Disclosure Program. The three agree that very few expats should ever be scared into an OVDP and if a disclosure program is needed, a Streamlined Disclosure is far for preferential. Ultimately what is needed right now from everyone concerned is unity. No matter your political affilication, the law needs to be changed. The law fails to raise revenue effectively and it is just morally wrong to tax people who are tax residents of outher countries. It is essential that everyone contact Congress and makes their voices be heard: Territorial Tax for Individuals must pass! Parent & Parent LLP 144 South Main Street Wallingford, CT 06492 (203) 269-6699 [email protected] https://youtu.be/qa5jeq3hM1s IRS Medic

#IRS Medic

0 notes

irstaxattrny · 6 years

Text

International Tax Reform December 2018 Updates FATCA - TTFI - GILTI

#IRS Medic

0 notes

mariamontgomeryclift · 6 years

Text

FBAR – 3 Top Questions About IRS Tax Penalties and FBAR Foreign Bank and Asset Reporting

FBAR – What is FBAR? How does FBAR effect my taxes?

Are you scared that you may be delinquent in reporting your foreign bank and financial accounts reports (FBAR)? Questions regarding whether you have to disclose or whether you should disclose? The best way to answer these questions is to consult with an experienced FBAR attorney. FBAR issues can be simple and some can be pretty complex. One universal consensus though is that FBAR requirements are often misunderstood leading to many reporting errors. FBAR filings are on the rise as FATCA and other international compliance efforts have raised awareness among taxpayers with offshore assets. The Foreign Account Tax Compliance Act (FATCA), which was passed as part of the HIRE Act, generally requires that foreign financial Institutions and certain other non-financial foreign entities report on the foreign assets held by their U.S. account holders or be subject to withholding on payments subject to withholding. The HIRE Act also contained legislation requiring U.S. persons to report, depending on the value, their foreign financial accounts and foreign assets.

Do I have to report and file FBAR? What are the requirements?

Many U.S. taxpayers have foreign financial accounts (investments, pension, banking, etc.), but know that if you do, you may have to report these accounts to the U.S. Treasury Department’s Financial Crimes and Enforcement Network (FinCEN) or face some hefty penalties. So, who must file an FBAR? A United States person that has a financial interest in or signature authority over foreign financial accounts must file an FBAR if the aggregate value of the foreign financial accounts exceeds $10,000 at any time during the calendar year. Reportable assets include the following:

deposit and custodial accounts held at foreign financial institutions

certain foreign stock and securities

foreign mutual funds

foreign-issued life insurance or annuity contracts with a cash value

other types of offshore assets

There are two forms that taxpayers who have foreign financial accounts or assets may have to submit. The first form is FinCen Form 114, Report of Foreign Bank and Financial Accounts. It is submitted separately from the tax return and can only be electronically filed. It is due April 15 of each calendar year but you can get an automatic extension to October 15. The second form, is Form 8938, Statement of Foreign Financial Assets, which has been in existence since 2011, as part of the new FATCA legislation and is included in the tax return. Just be aware of these common mistakes made on FBAR filings:

The $10,000 amount applies to the total of all of your foreign accounts, not just a single account and;

Life insurance policies, pension funds and inherited money are also subject to declaration.

It is important to know that if you have errors on your FBAR filing, you can still correct or file FBAR forms.

How do I file FBAR forms that are delinquent

If you are late, there are three ways to file FBAR forms: File them yourself online You can file FinCEN Report 114 online if: (1) you did not know you had to file FBAR forms, or if there was a good reason why you didn’t; (2) you already reported on your US tax returns and paid tax on the income from all of the foreign financial accounts to be named in your FBAR and (3) you are not under civil examination or investigation by the IRS, and you have not been contacted by them about any late FBARs. Use streamlined filing procedures If it is determined that your failure to report financial accounts and assets was non-willful, the streamlined procedure is an acceptable option. Be careful here because if there is any conduct that may show willfulness, it can expose the taxpayer to civil and criminal liabilities if filed in this manner. To clarify, use streamlined procedures if:

you unknowingly skipped declarations of your foreign assets and accounts.

you have made mistakes with filing FBAR forms in the past.

you have not already reported all your US tax returns and paid tax on the income from all of the foreign financial accounts to be reported in your FBAR declaration.

The streamlined filing procedure allows you to report or amend three years of tax returns and six years of delinquent FBAR statements without incurring a penalty. (See IRS instructions for streamlined filing procedures) If the IRS has initiated a civil examination of taxpayer’s returns for any taxable year, regardless of whether the examination relates to undisclosed foreign financial assets, the taxpayer will not be eligible to use the streamlined procedures. Similarly, a taxpayer under IRS criminal investigation is also ineligible to use the streamlined procedures. Enter the Offshore Voluntary Disclosure Program (OVDP) If your decision not to file was “willful,” then the Offshore Voluntary Disclosure Program is most likely the best option. In picking this option, the IRS allows you to declare everything that you knew you had to report, but didn’t and in return, the taxpayer will not face IRS criminal prosecution or substantial penalties. In order to make the OVDP voluntary disclosure, it must be (1) truthful, (2) timely and (3) complete. You must:

complete Form 14452, Foreign Account or Asset Statement.

review your Offshore Voluntary Disclosure Letter and Attachment.

evaluate and sign the Consent to Extend the Time to Assess Civil Penalties provided by 31 U.S.C. 5321 for FBAR Violations. (see more regarding OVDP forms and procedures on the IRS website)

If you enter this program you must submit the last eight years of tax returns. *This program is set to end September 28, 2018

Am I subject to tax penalties or criminal penalties for failure to file FBAR?

Failing to file an FBAR can carry a civil penalty of $10,000 for each non-willful violation. But if your violation is found to be willful, the penalty is the greater of $100,000 or 50 percent of the amount in the account for each violation. Each year not filed is a separate violation. (see IRS guidance and procedures applicable to FBAR cases) Criminal penalties for FBAR violations can include a fine of $250,000 and five years of imprisonment. If the FBAR violation occurs while violating other laws, the penalties are increased to $500,000 in fines and/or 10 years of imprisonment. If you decide to opt for the streamlined process, there is a possible five percent penalty on foreign accounts. If you enter the OVDP program, there is a twenty percent accuracy penalty on all taxes and even worse, there is a mandatory miscellaneous Title 26 offshore penalty of 27.5% on the highest account balance for the prior eight years. The IRS will not impose a penalty for the failure to file the delinquent FBARs if you properly reported on your U.S. tax returns, and paid all tax on, the income from the foreign financial accounts reported on the delinquent FBARs, and you have not previously been contacted regarding an income tax examination or a request for delinquent returns for the years for which the delinquent FBARs are submitted. Taxpayers needing assistance in dealing FBAR and reporting of foreign accounts and should seek the advice of a knowledgeable tax FBAR attorney. The Los Angeles Tax Attorneys at Delia Law have many years of tax fraud experience and will competently represent you before the IRS. Please call for a no-cost tax attorney consultation for tax resolution at (310) 494-0100. We look forward to helping you. This blog post is not intended as legal advice and should be considered general information only. Keywords, FBAR, FBAR Penalties, Offshore Voluntary Disclosure Program, Streamlined Filing Procedures, Foreign Bank and Financial Accounts, FBAR Attorney

The post FBAR – 3 Top Questions About IRS Tax Penalties and FBAR Foreign Bank and Asset Reporting appeared first on Delia Tax Attorneys San Diego IRS tax lawyers.

from Delia Tax Attorneys San Diego IRS tax lawyers https://ift.tt/2DRqVd7 via Tax Agencies San Diego

#tax agencies San Diego #state tax attorneys #us tax

0 notes

accountancyandtaxupdate-blog · 6 years

Photo

Paradise Papers: The role of the accountant

Containing a colossal 1.4 TB of data, the Paradise Papers is one of the biggest data leaks in history, second only to the Panama Papers. Like its predecessor, the Paradise Papers shine a light on the tax affairs of the world’s most rich and powerful, exposing their use of labyrinthine artificial structures to shelter their wealth in offshore tax havens. Among those named and shamed are the Queen, Justin Trudeau, Bono, and multinationals including Apple and Facebook. Law firm Appleby is at the heart of the leak and firmly denies any wrongdoing or illegal behaviour, stressing they advise clients on “legitimate and lawful ways to conduct their business”. Nonetheless, the leaks have reignited a public debate about the structures that permit tax avoidance and the professionals complicit in creating them, and has increased pressure on HMRC to clampdown on improper tax behaviour. View from industry Brian Palmer, tax policy expert at the ATT, commented: “In its purest form there is nothing wrong with tax planning when it is merely arranging one’s affairs in the most tax efficient manner under UK legislation.” Palmer added that over the last decade or so “there has been a conflation of the words avoidance and evasion, resulting in some perfectly legitimate tax planning being perceived to be inappropriate by the public and the media.” Although no apparent illegal activity has occurred, the release of this data still sparks questions about the laws and structures that permit tax avoidance. Furthermore, concerns have been raised over the role of professionals – namely lawyers and accountants – in recommending and facilitating such structures. Amongst the masses of data is a 60-page report on tax structuring produced for Blackstone by PwC on how to trim its tax bill and avoid paying stamp duty tax, according to the Guardian. At a later date Deloitte provided similar advice to the private equity group. The Guardian also revealed that Lewis Hamilton’s participation in a scheme to avoid paying taxes on his private jet was upon the advice of EY, which involved setting up artificial leasing and renting his own jet from himself. Although also not technically illegal, this is more contentious than other revelations as the artificial nature of the scheme opens it up to scrutiny from HMRC. Despite these activities being within the scope of the law, perceptions of the ultra-wealthy and multinationals not paying their fair share continues to be a source of public outrage, and is causing pressure to mount on tax professionals and the government to put an end to tax avoidance. Palmer added: “Calls will again be growing for Chancellor Philip Hammond to clamp down on the complex offshore tax structures of some wealthy Britons in his forthcoming Budget.” View from HMRC With support from the Prime Minister, HMRC has called on the BBC and the Guardian to hand over evidence from the Paradise Papers to help them investigate the allegations. The outlets have declined on the basis that the information is held by the International Consortium of Investigative Journalists. Nonetheless, in a meeting of the Public Accounts Committee earlier this week Jon Thompson, Chief Executive and Permanent Secretary of HMRC confirmed that the Revenue will be investigating each allegation, but will not be employing the aid of the Big Four due to too many conflicts of interest existing with the tax profession. Revelations made in the Paradise Papers will likely galvanise the taxman in its ongoing battle against tax evasion. In recent years HMRC has introduced a bevy of legislation and “increasingly punitive measures” to combat tax evasion, including the new Requirement to Correct (RTC) legislation and penalties for Failing to Correct (FTC) introduced in the Finance Bill 2017, as well as the new crime of failure to prevent tax evasion in the Criminal Finances Act 2017. Blick Rothenberg explains that RTC gives individuals with offshore arrangements a window of opportunity to make voluntary disclosures through the Worldwide Disclosure Facility (WDF) by 30th September 2018, after which any offshore discoveries will penalised more heavily. This date coincides with the first full automatic exchange of information under the Common Reporting Standards (CRS), which will grant HMRC unprecedented access to information about individuals with offshore interests. Fiona Fernie, partner and tax investigations specialist at Blick Rothenberg explained that although the Paradise Papers are undoubtedly impactful, “great amounts of information are already coming to HMRC as a result of the UK Foreign Account Tax Compliance Act (UK FATCA)”, involving UK crown dependencies and overseas territories, including Jersey, Guernsey, the Cayman Islands and Gibraltar. Fernie warned: “The combination of leaks and tools in HMRC’s arsenal is making it increasingly difficult for individuals to keep offshore matters secret, and those with offshore assets should urgently consider whether these require a review.” She added: “The risks of not identifying any errors or omissions and failing to correct them have increased dramatically with enormous potential penalties that could be in excess of 200% of any additional tax due.” “Additionally, claims of carelessness or innocent error will no longer be considered a valid defence.” It is unclear what actions, if any, HMRC will take in retaliation to the release of these 13.4m documents, but at the very least individuals and corporations will now have their tax affairs and offshore empires brought under a microscope. The post Paradise Papers: The role of the accountant appeared first on Accountancy Age.

https://www.accountancyage.com/2017/11/08/paradise-papers-role-accountant/

#HMRC #Tax Avoidance

0 notes

rhyspants13 · 6 years

Text

FBAR – 3 Top Questions About IRS Tax Penalties and FBAR Foreign Bank and Asset Reporting

FBAR – What is FBAR? How does FBAR effect my taxes?

FBAR filings are on the rise as FATCA and other international compliance efforts have raised awareness among taxpayers with offshore assets. The Foreign Account Tax Compliance Act (FATCA), which was passed as part of the HIRE Act, generally requires that foreign financial Institutions and certain other non-financial foreign entities report on the foreign assets held by their U.S. account holders or be subject to withholding on payments subject to withholding. The HIRE Act also contained legislation requiring U.S. persons to report, depending on the value, their foreign financial accounts and foreign assets.

Do I have to report and file FBAR? What are the requirements?

So, who must file an FBAR? A United States person that has a financial interest in or signature authority over foreign financial accounts must file an FBAR if the aggregate value of the foreign financial accounts exceeds $10,000 at any time during the calendar year.

Reportable assets include the following:

deposit and custodial accounts held at foreign financial institutions

certain foreign stock and securities

foreign mutual funds

foreign-issued life insurance or annuity contracts with a cash value

other types of offshore assets

The second form, is Form 8938, Statement of Foreign Financial Assets, which has been in existence since 2011, as part of the new FATCA legislation and is included in the tax return.

Just be aware of these common mistakes made on FBAR filings:

The $10,000 amount applies to the total of all of your foreign accounts, not just a single account and;

Life insurance policies, pension funds and inherited money are also subject to declaration.

It is important to know that if you have errors on your FBAR filing, you can still correct or file FBAR forms.

How do I file FBAR forms that are delinquent

If you are late, there are three ways to file FBAR forms:

File them yourself online

You can file FinCEN Report 114 online if: (1) you did not know you had to file FBAR forms, or if there was a good reason why you didn’t; (2) you already reported on your US tax returns and paid tax on the income from all of the foreign financial accounts to be named in your FBAR and (3) you are not under civil examination or investigation by the IRS, and you have not been contacted by them about any late FBARs.

Use streamlined filing procedures

If it is determined that your failure to report financial accounts and assets was non-willful, the streamlined procedure is an acceptable option. Be careful here because if there is any conduct that may show willfulness, it can expose the taxpayer to civil and criminal liabilities if filed in this manner.

To clarify, use streamlined procedures if:

you unknowingly skipped declarations of your foreign assets and accounts.

you have made mistakes with filing FBAR forms in the past.

you have not already reported all your US tax returns and paid tax on the income from all of the foreign financial accounts to be reported in your FBAR declaration.

If the IRS has initiated a civil examination of taxpayer’s returns for any taxable year, regardless of whether the examination relates to undisclosed foreign financial assets, the taxpayer will not be eligible to use the streamlined procedures. Similarly, a taxpayer under IRS criminal investigation is also ineligible to use the streamlined procedures.

Enter the Offshore Voluntary Disclosure Program (OVDP)

If your decision not to file was “willful,” then the Offshore Voluntary Disclosure Program is most likely the best option. In picking this option, the IRS allows you to declare everything that you knew you had to report, but didn’t and in return, the taxpayer will not face IRS criminal prosecution or substantial penalties.

In order to make the OVDP voluntary disclosure, it must be (1) truthful, (2) timely and (3) complete. You must:

complete Form 14452, Foreign Account or Asset Statement.

review your Offshore Voluntary Disclosure Letter and Attachment.

evaluate and sign the Consent to Extend the Time to Assess Civil Penalties provided by 31 U.S.C. 5321 for FBAR Violations. (see more regarding OVDP forms and procedures on the IRS website)

If you enter this program you must submit the last eight years of tax returns.

*This program is set to end September 28, 2018

Am I subject to tax penalties or criminal penalties for failure to file FBAR?

Criminal penalties for FBAR violations can include a fine of $250,000 and five years of imprisonment. If the FBAR violation occurs while violating other laws, the penalties are increased to $500,000 in fines and/or 10 years of imprisonment.

If you decide to opt for the streamlined process, there is a possible five percent penalty on foreign accounts.

If you enter the OVDP program, there is a twenty percent accuracy penalty on all taxes and even worse, there is a mandatory miscellaneous Title 26 offshore penalty of 27.5% on the highest account balance for the prior eight years.

The IRS will not impose a penalty for the failure to file the delinquent FBARs if you properly reported on your U.S. tax returns, and paid all tax on, the income from the foreign financial accounts reported on the delinquent FBARs, and you have not previously been contacted regarding an income tax examination or a request for delinquent returns for the years for which the delinquent FBARs are submitted.

Taxpayers needing assistance in dealing FBAR and reporting of foreign accounts and should seek the advice of a knowledgeable tax FBAR attorney. The Los Angeles Tax Attorneys at Delia Law have many years of tax fraud experience and will competently represent you before the IRS. Please call for a no-cost tax attorney consultation for tax resolution at (310) 494-0100. We look forward to helping you.

This blog post is not intended as legal advice and should be considered general information only.

Keywords, FBAR, FBAR Penalties, Offshore Voluntary Disclosure Program, Streamlined Filing Procedures, Foreign Bank and Financial Accounts, FBAR Attorney

The post FBAR – 3 Top Questions About IRS Tax Penalties and FBAR Foreign Bank and Asset Reporting appeared first on Delia Tax Attorneys.

Source: https://losangeles-tax-attorneys.com/fbar-irs-tax-penalties-fbar-foreign-bank-and-asset-reporting/

0 notes

jajaanson90 · 6 years

Text

Bowman Offshore Bank Transfers on Offshore Tax Problems before and After IRS Closes Offshore Voluntary Disclosure Program

It's not too late to correct your U.S. tax filing compliance errors related to offshore holdings, but time is quickly running out. On March 13, 2018, the Internal Revenue Service announced that the Offshore Voluntary Disclosure Program (OVDP) started in March 2009 will finally come to a close on September 28, 2018. After that date, taxpayers with noncompliant foreign financial matters must resort to other programs, other traditional procedures and new procedures to be announced by the IRS for dealing with undisclosed offshore accounts and holdings.

Qualifying for the OVDP

In order to qualify for the soon-to-expire OVDP, a U.S. taxpayer on or before September 28, 2018, must make a complete disclosure to the IRS. This will require that a complete Offshore Voluntary Disclosure conforming to certain requirements is received or postmarked by September 28, 2018. The disclosure may not be "partial, incomplete or placeholder submission."

On or before September 28, 2018, a taxpayer seeking admission to the OVDP must provide the following:

The Offshore Voluntary Disclosure Letter and attachments. This submission includes the following information:

· Taxpayer identifying information (name, address, SSN, date of birth, passport number, occupation)

· Bank names, name on account, account numbers

· Identification of the source of funds in the account

· Whether the account records are "susceptible to being turned over to the U.S. government pursuant to an official request"

· Whether there has been an objection to the official request and if so was the U.S. given notice of the objection?

· Whether the taxpayer or "any related entities" are under IRS audit or criminal investigation by the IRS "or any other enforcement authority"

· Whether the taxpayer believes that the IRS has obtained information regarding the tax liability at issue

· An estimate of the highest aggregate value of the offshore accounts

· An estimate of the total unreported income from the offshore account

For each disclosed account:

· The name and address of the financial institution

· The open and closing dates

· The names of the persons who advised or assisted in the opening of the account and an explanation of the communications with those people

· Whether those persons met or called the taxpayer in the U.S.

· Whether anyone suggested the use of entities or particular foreign countries to avoid disclosure of the ownership of the account

· Whether anyone suggested surreptitious means for communicating with the bank

· Did anyone suggest moving the funds in the account to another bank or a different country?

· How were funds in the account accessed?

· Were funds moved to the U.S.?

· The names of all the persons and entities "affiliated" with the account

Do Not Delay Filing

Many times in the past, a taxpayer has made an incomplete OVDP application to the IRS in order to meet some perceived deadline. For instance, if concerned that the IRS would receive information about the taxpayer's specific noncompliance, the taxpayer may have made a "quickie" disclosure providing some but not all required information. Historically the IRS has been very flexible in granting extensions to a taxpayer to provide the balance of the required information. With these new requirements of a "complete" disclosure by September 28, the flexibility appears to have evaporated.

Securing "complete" information to make a "complete" disclosure is not easy. Foreign banks, especially small institutions, are not quick to react to a request for information. Closed accounts will receive even slower consideration. Accordingly, if a disclosure is anticipated, the search for bank records should start immediately.

What happens if information is incomplete? Guidance has not been provided, but it is possible that "substantial" completeness may be sufficient. Perhaps disclosure of the name of the financial institution, location, owner of record, estimated date of opening and closing, and a reasonable estimate of highest balances may suffice where it can be demonstrated that a real but unsuccessful effort was made to timely secure account information.

Note: "Substantial" completeness, to be acceptable by the IRS, means that accounts that should have been obvious to the taxpayer are not omitted. The omission of an account that the taxpayer recently accessed or transferred to another bank will likely be looked upon unfavorably.

Missing the Deadline Is Not Fatal

Should a taxpayer with offshore compliance issues not meet the September 28, 2018, deadline, other alternatives may be available to resolve the problem.

The IRS has announced that the Streamlined Filing Compliance Procedures (the "Streamlined Procedures") and the Delinquent International Information Return Submission Procedures will remain available after the September 28 deadline. That means that the existing programs for filing delinquent Report of Foreign Bank and Financial Accounts (FBAR) and other international information returns remain available and a penalty-free filing can be made under certain circumstances. Streamlined Procedures for U.S. taxpayers residing in and outside the United States are available, permitting the filing of income tax returns for only three years and FBARs for six years with either a 5 percent or no penalty. However, taxpayers participating in the Streamlined Procedures must have a situation which permits them to file, under penalties of perjury, a certification that their tax compliance errors were not willful. Any individual who meets that qualification would ordinarily not want to participate in the 2014 OVDP, in most events.

The 2014 OVDP provides many benefits, including an assurance of no criminal prosecution. However, that assurance comes with a significant price, including the payment of a penalty of between 27.5 percent and 50 percent of the highest value of offshore accounts which were undisclosed. In addition, a participant in the 2014 OVDP must file eight years' worth of amended income tax returns and pay the tax, a 20 percent accuracy-related penalty and interest. Also, FBARs and other foreign financial reports are required for the previous eight years. This can be a very heavy price to pay, but is an excellent resolution for someone who has engaged in willful or criminal conduct. Those individuals who have not engaged in willful or criminal conduct would rarely want to utilize the "benefits" of the 2014 OVDP and would opt for the Streamlined Procedures.

As stated, the IRS has reported that the existing Streamlined Procedures will remain in effect. In addition, the IRS has stated it will issue new guidelines for dealing with undisclosed foreign accounts. In the past, the IRS has refined the then-existing OVDP. For instance, the Miscellaneous Offshore Penalty (on the highest value of noncompliant accounts) started at 20 percent in 2009, was escalated to 25 percent, then 27.5 percent with a 50 percent penalty for accounts related to certain "bad" banks. It is unlikely that any new program will simply increase the penalty. Any new initiative may well include many new components and certainly a much higher financial cost.

Aside from the potential new programs that will be forthcoming, taxpayers who do not qualify for the Streamlined Procedures may still make a voluntary disclosure provided their income is from legal sources and the taxpayer has not been contacted by the IRS. The voluntary disclosure will be a major factor in whether the Department of Justice (DOJ) decides to bring criminal proceedings. Historically, individuals making a truthful, complete and accurate voluntary disclosure are not criminally prosecuted; however, they do face the prospect of significant civil penalties including the potential for a civil fraud penalty and large FBAR penalties. Nonetheless, the prospect of eliminating the likelihood of criminal prosecution makes the traditional voluntary disclosure program very attractive for certain taxpayers.

New Means and Methods for the IRS to Secure Information of Offshore Accounts

The IRS announced that it was stopping the 2014 Voluntary Disclosure Program in part because the number of individuals applying to the program has steadily declined. In addition, the IRS stated that it is receiving very significant information about taxpayers with respect to information received under the Foreign Account Tax Compliance Act (FATCA), the network of intergovernmental agreements between the U.S. and partner jurisdictions, automatic third-party account reporting and other data-rich sources, such as the DOJ Swiss Bank Program and various John Doe summonses. This information is used to initiate examinations and investigations of noncompliant taxpayers. For instance, the IRS/DOJ continues to negotiate settlements with numerous financial institutions including Swiss and Israeli banks. For example, Bank Hapoalim is in the midst of negotiating a settlement with the DOJ that will likely include the disclosure of U.S. customer account information.

In addition, the IRS has recently been issuing letters to taxpayers who started the Offshore Voluntary Disclosure process and stopped for some undisclosed reason. Those taxpayers are being asked to make a submission under the Streamlined Procedures, file amended returns or explain why they are compliant with IRS laws. It is interesting to note that the IRS in these recent letters to taxpayers did not offer the opportunity to reapply for the OVDP.

#offshore bank transfers #bowman offshore transfer #bowman transfer

0 notes

dreamilycrazybird · 6 years

Text

#Lincoln international #tax #lawyers discusses #InternationalTaxLawyers #Olathe #Kansas http://ow.ly/E29p30jMpUs

WELCOME TO SHERAYZEN LAW OFFICE, LTD.!

Our firm offers the following legal services to its individual and business tax clients in the United States and across the world:

International Tax Compliance: FATCA, FBAR (Report on Foreign Bank and Financial Accounts), foreign entity ownership (e.g. Form 5471, Form 8865, 8858), foreign trust ownership and beneficial interests (Form 3520), foreign gifts, foreign inheritance and other international tax compliance services generally offered by International Tax Lawyers Olathe

Offshore Voluntary Disclosures: OVDP, Streamlined Domestic Offshore Procedures, Streamlined Foreign Offshore Procedures and other offshore voluntary disclosure paths offered by International Tax Lawyers Olathe

International Tax Planning: business tax planning, individual tax planning combined with estate planning and related services offered by International Tax Lawyers Olathe

Our typical clients in Olathe are:

Businesses headquartered outside of the United States with U.S. operations in Olathe, Kansas;

Nonresident aliens with U.S. business and/or investment activities in Olathe, Kansas;

High-net-worth individuals in Olathe, Kansas affected by the FBAR, foreign trust, and other foreign-asset reporting requirements;

Nonresident aliens that own U.S. real estate in Olathe, Kansas;

U.S. citizens and residents from Olathe, Kansas who are living and/or working abroad;

U.S. citizens and residents in Olathe, Kansas with non-U.S. business and/or investment activities;

Businesses headquartered in the United States, and/or in Olathe, Kansas Colorado with foreign operations;

Sherayzen Law Office is an international tax law firm that fits well within the search for International Tax Lawyers Olathe, Kansas for three reasons:

The definition of International Tax Lawyers Olathe includes any international tax lawyer who is licensed to practice in any of the fifty states of the United States and offers international tax law services to clients who reside in Olathe, Kansas.

Sherayzen Law Office offers international tax services that fall within the definition of the International Tax Lawyers Olathe, Kansas.

The communication mediums of Sherayzen Law Office are based on modern technology and fall within the communication mediums generally utilized by International Tax Lawyers Olathe, Kansas.

#tax #taxlaw #TaxLawAttorney #kansas

0 notes

bambridgeaccountants · 6 years

Text

Offshore Voluntary Disclosure Program Closing: OVDP

The Offshore Voluntary Disclosure Program is a program designed specifically for taxpayers with exposure to potential criminal liability and/or civil penalties due to a willful failure to report foreign financial assets and pay all tax due in respect to those assets.

On the 28th September 2018 the IRS will be closing the 2014 OVDP. This is due to a significant decline in the number of taxpayers participating as well as an increase in awareness of offshore tax and reporting obligations.

It should be notes, that the closing of the 2014 OVDP does not end nor lessen the IRS’s priorities towards offshore tax compliance. The IRS enforce offshore compliance with tax and FBAR requirements using information received under the Foreign Account Tax Compliance Act (FATCA) and so on.

Deadline for submitting a 2014 OVDP

All offshore voluntary disclosures conforming to the requirements of the 2014 OVDP filing procedure must be received or post marked by the 28th September 2018.

0 notes

elizabethcariasa · 6 years

Text

IRS ending foreign account disclosure program in September

Cover photo from 2017 report Offshore Shell Games by ITEP and PIRG

Offshore tax havens.

The phrase immediate conjures up images of dubious financial guys who've traded in their high-powered jobs and three-piece suits for floral print shirts and umbrella-shaded drinks on a tropical beach, all funded by cash they stashed in island-based accounts, hidden from the U.S. tax collector.

Sometimes that's true.

Everyone knows by now of the scrutiny given to Cayman Island banks, as well as the hidden accounts revealed by the Panama Papers.

But offshore in Internal Revenue Service parlance means any location outside United States boundaries.

Again, everyone by now knows about the fabled secret Swiss bank accounts and similar ones in neighboring Lichtenstein and a tiny island in the Irish Sea.

The IRS certainly knows about all these places where U.S. taxpayers stash their cash. And they do all they can to find the money and get the taxes due.

In addition to employing traditional enforcement actions against offshore accounts, the IRS has used since 2009 a voluntary program — often referred to, much to the IRS' chagrin, as a tax amnesty — to encourage foreign account owners to report their offshore holdings and get right with the tax collector.

That option, however, will end in September.

Foreign holdings, U.S. taxes: One method the IRS uses to find and collect taxes on foreign accounts is the Foreign Bank and Financial Accounts reporting, commonly referred to as FBAR.

You must file this report (Form 114 submitted to the Financial Crimes Enforcement Network, or FinCEN) if you are, per IRS/Banking Secrecy Act language, a "United States person [who] had a financial interest in or signature authority over at least one financial account located outside of the United States" and at any time during the tax year the aggregate value of the account or accounts exceeded $10,000.

Then there's the Foreign Account Tax Compliance Act, known as FATCA. Since 2010, FATCA has required additional non-U.S. account reporting.

If you don't comply with these laws, you'll face very costly penalties and potential criminal prosecution.

IRS lets account owners come clean: Sometimes folks just didn't/don't know about these laws. In other cases, though, they intentionally flout them. I know. Tax cheats! Amazing.

Whatever the reason for noncompliance regarding overseas accounts, the IRS decided in 2009 to add a tax carrot to its foreign account enforcement sticks.

The agency created the Offshore Voluntary Disclosure Program, or OVDP, to encourage people to 'fess up about their offshore accounts and pay Uncle Sam the taxes due on that money.

That first OVDP was tweaked and extended over the years. The current offshore account reporting program was put in place in 2014.

Although the IRS hates the word amnesty, it works much the way of state-level tax forgiveness programs. Basically, a person who has a heretofore unknown to the IRS foreign account(s) can tell the taxman about the money, pay due taxes (and interest) at a reduced penalty rate and avoid criminal charges.

Self-reporting success: Over the years, the various OVDP versions have been remarkably successful.

Since the OVDP's initial launch almost a decade ago, the IRS says more than 56,000 taxpayers have used one of the programs to comply voluntarily. All told, these foreign account owners have paid a total of $11.1 billion in back taxes, interest and penalties.

But after peaking in 2011, when around 18,000 taxpayers came forward about their overseas account ownership, the number of self-reporters has steadily declined. In 2017, there were only 600 disclosures via the OVDP.

So, says the IRS, it's time to end the program.

The IRS announced this week that it will be ramping down the current OVDP over the next few months, with closure of the program scheduled for Sept. 28.

This advance alert of the coming closure, says the IRS, should give any U.S. taxpayers with undisclosed foreign financial assets plenty of time to take advantage of the OVDP before it closes.

"Taxpayers have had several years to come into compliance with U.S. tax laws under this program," said Acting IRS Commissioner David Kautter. "All along, we have been clear that we would close the program at the appropriate time, and we have reached that point. Those who still wish to come forward have time to do so."

Other compliance options remains: The IRS also operations a separate program, the Streamlined Filing Compliance Procedures, for taxpayers who might not have been aware of their filing obligations.

This program has helped about 65,000 additional taxpayers come into compliance, according to the IRS.

The streamlined system will remain in place. For now.

The IRS says it will continue to monitor this program's effectiveness and, as with OVDP, it may end the streamlined filing procedures at some point.

And don't think that the end of the OVDP and possible similar phase out of the streamlined procedures mean that folks can go back to their former, secretive tax-hiding account ways.

The IRS has other tools to combat offshore tax avoidance and it reminds taxpayers that it will continue to use them. They include continuing taxpayer education (like this blog post you're reading), leads from whistleblowers (that sometimes pay off very nicely), civil examination (aka audits) of returns and criminal prosecutions in cases where flagrant offshore tax evasion is discovered.

Criminal tax investigations: On the criminal side, the IRS' Criminal Investigation (CI) unit has since 2009 indicted 1,545 taxpayers on violations related to international activities, of which 671 taxpayers were indicted on international criminal tax violations.

"The IRS remains actively engaged in ferreting out the identities of those with undisclosed foreign accounts with the use of information resources and increased data analytics," said CI chief Don Fort. "Stopping offshore tax noncompliance remains a top priority of the IRS."

The IRS has more details on options available for U.S. taxpayers with undisclosed foreign financial assets.

You've been warned. Now take advantage of the OVDP while you still can.

You also might find these items of interest:

3 costs of tax evasion: Countries lose more than money

Global income inequality tied to worldwide tax havens

States line up to be domestic tax havens for U.S. rich

// <![CDATA[ // <![CDATA[ // &lt;![CDATA[ // &amp;lt;![CDATA[ // &amp;amp;lt;![CDATA[ // &amp;amp;amp;lt;![CDATA[ // &amp;amp;amp;amp;lt;![CDATA[ // &amp;amp;amp;amp;amp;lt;![CDATA[ // &amp;amp;amp;amp;amp;amp;lt;![CDATA[ // &amp;amp;amp;amp;amp;amp;amp;lt;![CDATA[ // &amp;amp;amp;amp;amp;amp;amp;amp;lt;![CDATA[ (adsbygoogle = window.adsbygoogle || []).push({}); // ]]&amp;amp;amp;amp;amp;amp;amp;amp;gt; // ]]&amp;amp;amp;amp;amp;amp;amp;gt; // ]]&amp;amp;amp;amp;amp;amp;gt; // ]]&amp;amp;amp;amp;amp;gt; // ]]&amp;amp;amp;amp;gt; // ]]&amp;amp;amp;gt; // ]]&amp;amp;gt; // ]]&amp;gt; // ]]&gt; // ]]> // ]]>

0 notes