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Archive for the ‘International Estate Planning’ Category


Trust and Estate Attorney Orlando
Published: August 29th, 2013

By: Matthew J. Ahearn

Today, the United States Treasury Department and the Internal Revenue Service issued a very significant and consequential ruling, Revenue Ruling 2013-17, addressing tax issues arising from the recent U.S. Supreme Court decision of U.S. v. Windsor, 133 S. Ct. 2675, issued on June 26, 2013. For federal tax purposes, the IRS will now recognize all same-sex […]

Swiss Adopt Banking Protocol Allowing U.S. to Request Information

Published: March 30th, 2012

By: Brad Gould

On March 5, the Swiss parliament adopted an amended ratification of the 2009 Protocol to the Swiss-US Income Tax Treaty. The protocol was signed by United States and Swiss tax officials on September 23, 2009 to allow a greater tax information exchange between the countries in the aftermath of the UBS tax evasion controversy and […]

Foreign Financial Assets, Form 8938 Instructions

Published: March 5th, 2012

By: Dana M. Apfelbaum

At the beginning of 2011, we posted about the new reporting requirement for certain individuals who own foreign assets over a certain threshold. For tax years beginning after March 18, 2010, citizens, resident aliens and certain nonresident aliens with specified foreign assets with an aggregate value exceeding the threshold must file the new Form 8938 […]

New Offshore Voluntary Disclosure Program for 2012

Published: January 10th, 2012

By: Brad Gould

Yesterday, the IRS started the Offshore Voluntary Disclosure Program (2012 OVDP), which is a modified continuation of the 2011 Offshore Voluntary Disclosure Initiative (2011 OVDI).  The IRS will also release a new FAQ and provide additional details of 2012 OVDP on its website in the coming months. 2012 OVDP comes on the heels of last […]

IRS Extends Offshore Reporting Deadline

Published: August 29th, 2011

By: Brad Gould

Due to Hurricane Irene, the IRS extended the deadline for participating in the Offshore Voluntary Disclosure Initiative (OVDI) from August 31, 2011 to September 9, 2011.  The new deadline applies both to submissions into the program and requests for a 90 day extension. For details on the OVDI program, please see our previous posts located […]

Offshore Voluntary Disclosure Initiative

Published: June 27th, 2011

By: Brad Gould

On April 11, we summarized the 2011 Offshore Voluntary Disclosure Initiative (OVDI). Last week, the Internal Revenue Service updated its online FAQ, which provided several changes or expansions to the program. First, in limited situations, the IRS will consider up to a 90-day extension to enter the program upon a taxpayer’s request and a good […]

The IRS Offshore Voluntary Disclosure Initiative

Published: April 11th, 2011

By: Brad Gould

In February, the IRS announced the 2011 Offshore Voluntary Disclosure Initiative (OVDI). The purpose of OVDI is to bring taxpayers that used undisclosed foreign assets to avoid tax into compliance with U.S. tax laws. OVDI, which is similar to the 2009 Offshore Voluntary Disclosure Program, ends on August 31, 2011.   OVDI provides taxpayers with […]

Foreign Financial Assets: New Reporting Requirements

Published: January 10th, 2011

By: Brad Gould

Dana M. Trachtenberg, Esq. contributed to this post. Prior to this year, if you owned foreign financial assets totaling at least $10,000, you had to meet one set of reporting requirements, mandating disclosure of any account in which you had a financial interest or as to which you had signatory or other authority on Form […]