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Benefits of Offshore Investing
http://lippmancpas.comWalnut Creek, CA
Offshore Investing
• Benefits of Offshore Investing
• Higher Return on Investment (ROI)
• Mitigate Risk
• Convenience
• Tax Shelters
Offshore Investing
• Failure to comply could:
• Negate profits & result in loss of investment• Deem your activities illegal• Result in large monetary fines (possibly more
than your investments, everything that you have or will have)
• Result in loss of green card• Destroy your legacy
Your Duties• FBAR (Foreign Bank Account Reports Form TD F 90-
22.1)• Penalty
• Reporting Foreign Income Generated from Offshore Financial Institution• Who is Taxed?
• Taxes Covered • Interest Income Generated From Foreign Account• Special Rules for Foreign Mutual Funds
Passive Foreign Investment Company (PFIC)
• What is a PFIC?
• Significance of PFIC Tax
• Avoiding PFIC Rules• QEF Election• Market to Market Election
Liabilities• Tax Liability Associated With Foreign Account
• Criminal Penalties Associated with Not Disclosing Income
• Attempt to Evade the Payment of Tax• Filing of a False and Fraudulent Tax Return
• Civil Penalties
United States (U.S.) Enforcement
• Why and How?
• Bank Summons
• Basler Kantonalbank• Credit Suisse Group AG & Privite Advisors• HSBC• Israeli Bank• Neue Zaercher Bank• UBS AG & Swiss Financial Advisers AG• Bank Hapoalim• Cantonal Banks
• Joint Country Criminal Investigation
United States (U.S.) Enforcement (cont.)
• Government Data/Revenue Collection Programs• OVDI & OVDI II
• Criminal Prosecutions• Charges• Convictions & Pleas
• Civil Enforcement• Audits• 3rd Party Information• Criminal Consequences
United States (U.S.) Enforcement (cont.)
• Immigration Problem
• Deportation• Federal or State Tax Crime• Incarceration • Fines
Unfiled Tax Returns
• Statute of limitations:• Criminal• Civil
• Lost records• Basis [adjusted cost] of assets sold
What if you can’t pay?
• Additional time to pay• Installment payment plans• Offer In Compromise (OIC)• Bankruptcy
• Liquidation [Chapter 7]• Reorganization [Chapters 11 & 13]
What You Can Do!
• IRS Voluntary Disclosure• Amnesty Programs
• State Considerations• Dual Citizenship Consideration
How We Can Help
• Over 30 years protecting your rights in Tax Law
• Review your accounts• Help you comply with the law• Determine best approach to deal with U.S.
Government
Contact Information180 Montgomery StreetSuite 1950San Francisco, CA 94104888.829.3325415.394.7200www.stevemoskowitz.com
About Wayne Lippman
https://www.facebook.com/lippman.associates.CPAs
https://www.youtube.com/waynelippman
http://waynelippman.com
https://twitter.com/waynelippman
Wayne Lippman has forty years of experience in public accounting including twenty years with Price Waterhouse, where he served as a tax partner in the San Francisco and Oakland offices. He was previously Managing Tax Partner of the Walnut Creek office of Price Waterhouse.
http://Waynelippman.wordpress.com