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No escape from the IRS

28 June 2011 / David Treitel
Issue: 4310 / Categories: Comment & Analysis , Admin , Income Tax , Residence & domicile
DAVID TREITEL looks at the change made by the IRS to the American amnesty and at the extra reporting requirements

KEY POINTS

  • US amnesty closes on 31 August.
  • Penalties have been recently reduced to as low as 5%.
  • Penalties are unlikely ever to be as low again.
  • Substantial new reporting of non-US assets is required.


Just as HMRC have been concentrating resources on offshore accounts the United States Internal Revenue Service (IRS) is equally focused on fighting offshore tax evasion.
United States citizens and green card holders are always chargeable to US tax on worldwide income and gains. Consequently most such ‘US persons’ here in the UK have pretty much mandatory annual requirements to file not only US income tax returns but also annual information returns reporting non-US assets.

In my article ‘Your last best chance?’ I discussed...

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