Tax E-lert: Developments in the Domestic & International Realm for the Third Quarter


The U.S. Department of Justice has charged a Florida man with making a false submission in relation to their Streamline Domestic Offshore Procedure filing. This is the first time such charges have been made. The streamline program was created for individuals who failed to report offshore accounts without intent to defraud the government. Along those lines individuals who entered the Offshore Voluntary Disclosure Program, may be receiving what the government calls a “soft Letter” from the IRS warning them that the IRS may be requesting future audits to make sure the taxpayer is complying with their reporting requirements. 

The U.S. government is increasing its financial requirements to obtain an EB5 investor visa from $1 million to $1.8 million, or from $500,000 to $900,000 in a targeted employment area. This change will go into effect in November of this year. Let us know if we can help your clients plan for their pre-immigration tax needs. 

The Treaties between the U.S. and Japan went into effect on August 30, 2019. The U.S. treaty with Spain will go into effect on November 27, 2019.


A number of countries have entered into exchange of information agreements with Switzerland. Among those countries are: Argentina, Brazil, Chile, China Costa Rica, Mexico and Uruguay. Along those lines, France and Panama have signed an exchange of information agreement.

Ruben Gotlieb
GrayRobinson, P.A.
333 S.E. 2nd Avenue
Suite 3200
Miami, Florida 33131
P: 305-416-6880
F: 305-416-6887