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Taking the “F” Out of FBAR November 3-8, 2011 A Presentation by:

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1 Taking the “F” Out of FBAR November 3-8, 2011 A Presentation by:

2 Offshore Investing Benefits of Offshore Investing Higher Return on Investment (ROI) Mitigate Risk Convenience Tax Shelters

3 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

4 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

5 Passive Foreign Investment Company (PFIC) What is a PFIC? Significance of PFIC Tax Avoiding PFIC Rules QEF Election Market to Market Election

6 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

7 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

8 United States (U.S.) Enforcement (cont.) Government Data/Revenue Collection Programs OVDI & OVDI II Criminal Prosecutions Charges Convictions & Pleas Civil Enforcement Audits 3 rd Party Information Criminal Consequences

9 United States (U.S.) Enforcement (cont.) Immigration Problem Deportation Federal or State Tax Crime Incarceration Fines

10 Unfiled Tax Returns Statute of limitations: Criminal Civil Lost records Basis [adjusted cost] of assets sold

11 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]

12 What You Can Do! IRS Voluntary Disclosure Amnesty Programs State Considerations Dual Citizenship Consideration

13 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

14 Contact Information 180 Montgomery Street Suite 1950 San Francisco, CA 94104 888.829.3325 415.394.7200

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