Ontario Global Research

The mechanisms of secrecy

What is FATCA?




In January 2012 the U.S. Internal Revenue Service reinstated its previous successful Voluntary Disclosure Program (VDP); a half-hearted amnesty program with no guarantees of non-prosecution for tax evasion. The IRS had two previous VDP’s; one in 2009 and 2011. The previous programs raked in a combined total of over 4 billion dollars from tens of thousands of now reformed tax evaders. But, the previous VDP’s were prior to the IRS negotiating and/or entering into Intergovernmental Agreements with over 50 countries. So, the overwhelming majority of reformed tax dodgers were not prosecuted.

SWITCH: prisoner

Many U.S. citizens of the Jewish faith are also citizens of Israel. This dual citizenship affords U.S. citizens, whether resident in the U.S. or Israel, access to Israel’s banking system.

Anticipating eventual capture dozens of U.S. citizens with accounts in two Israeli Banks (Bank Leumi & Mizrahi Tefahot Bank) retained Lawyers and applied under the 2012 VDP and were accepted by the IRS. Then on 7th March 2013 Lawyers for the VDP participants stated they had received letters from the IRS informing them all of their clients were no longer acceptable for the VDP: leaving them exposed to prosecution. Many having already settled their back taxes with the IRS. The IRS gave no explanation for the reversal and the Lawyers did not speculate.



We have to wait to see how this incident further develops; if the IRS ever provides an explanation. But maybe this is the beginning of the end for the Voluntary Disclosure Program for those with bank accounts in countries negotiating a FATCA Intergovernmental Agreement (IGA) with the IRS. Maybe the U.S. government is going to count any voluntary surrender, with an account in an “in IGA negotiations” as being already caught and subject to prosecution?

What do you think?

Quanta Consulting Limited provides HNW & UHNW with offshore structures and private banking services for assets protection and wealth preservation; including U.S. citizens. Quanta does not function as a offshore Trustee. With offshore corporate laws there is no reason to use a trust as a protection or preservation structure. And for generational wealth preservation a Private Family Foundation is far superior to an offshore Trust.

Also, Frank Dosebio, director of business filings at Evedex LLC says:“The only document required to be filed in Delaware to create the LLC, is the Certificate of Formation. Unlike other states, Delaware requires very little information to be made public in order to form an LLC. The Certificate of Formation filed with the Delaware Secretary of State is required to contain only two articles: the name of the Delaware LLC and the address of the Delaware LLC’s registered office and the name and address of the Delaware LLC’s registered agent in Delaware. At Evedex LLC we serve as registered agent for more than 3000 companies.


Number of comments: 10

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