Why Use Our Services
Michael B. Nelson has been representing clientele in confidential communications for over 35 years with the skills, knowledge and experience seeking to bring clients into compliance with the U.S. Treasury and the Internal Revenue Service.
U.S. Tax Compliance issues are developing at a rapid pace; far faster than other countries. These other countries are looking towards the U.S. for their possible tax compliance models. We are acutely aware and familiar with the U.S. compliance forms, becoming current with filing, including the Quiet Filing and Amnesty alternatives. Should the IRS make contact with you first, then you really need to urgently contact us before any information or communications take place between the IRS and yourself. In May of 2013, the U.S. Internal Revenue Service has opened cases and begun investigations based on what it calls a “substantial amount” of information it has received on offshore companies, trusts and related bank accounts Singapore, the British Virgin Islands, the Cook Islands and the Cayman Islands.
“It’s enough for us to move on in several cases at least,” Michael Danilack, an IRS deputy commissioner for international issues. “When we see information like that, we usually will pursue what we can on both the owner as well as any advisers that may be involved.”
We at Michael B. Nelson, Inc. believe that it is just a matter of time before the U.S. Treasury learns of you, your entities and offshore bank accounts through their information mining techniques, collaboration with other countries including tax haven jurisdictions, audits of advisers and their clients which lead to you.
Our clients include asset protection advisors, foreign lawyers, offshore trust companies, recent immigrants, foreign banks, Green-Card holders and U.S. Citizens.
In a surprising, yet expected, move, on October 24, 2013, the U.K. has now entered into a historic exchange of information agreement with the the Isles of Guernsey and Jersey have followed the Isle of Man in signing formal inter-governmental agreements with the UK implementing the automatic exchange of tax information.
All three Crown Dependencies announced in March this year their willingness to sign the deals, sometimes called ‘UK FATCA agreements’ because they closely follow the disclosure provisions and timetable of the US Foreign Account Tax Compliance Act.Financial information on UK resident taxpayers holding accounts in any of the Crown Dependencies will be supplied to HM Revenue and Customs starting from January 2015. The standard reporting schedule requires information for the 2014 and 2015 calendar years to be reported by 30 September 2016. After that, reporting will take place within nine months of the relevant calendar year end. No information for 2013 will be reported. Similar to the U.S. Amnesty model, UK residents with assets in the Crown Dependencies can voluntarily notify them to HMRC. They may get reduced penalties as a result, though with no guarantees of immunity from prosecution. The UK Treasury said the ‘historic’ agreements represented a ‘step change in HMRC’s ability to clamp down on tax evasion’. It hopes to sign similar agreements with British Overseas Territories soon.
If you have financial arrangements or business in any of these Territories, you should immediately determine if you are in compliance since the UK and the US share a robust exchange of information agreement, then plan to be in compliance. The 14 British Overseas Territories are: The 14 Overseas Territories are:
- British Antarctic Territory
- British Indian Ocean Territory
- The British Virgin Islands
- The Cayman Islands
- The Falkland Islands
- The Pitcairn, Henderson, Ducie & Oeno Islands
- Saint Helena, Ascension and Tristan da Cunha (including Gough Island Dependency)
- South Georgia and the South Sandwich Islands
- Sovereign Base Areas, Akrotiri and Dhekelia (on Cyprus)
- The Turks & Caicos Islands
If you are concerned about your risk and exposure, please contact us for a discreet review of your total situation and allow us to make constructive and, if you wish, actual compliance preparation and filing before the IRS ultimately makes contact with you first. Once a department of the U.S. Government makes contact with you on the matter of compliance, your options become very limited.