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Streamlined Foreign Bank Account Report (FBAR) Filing Compliance Procedure FAQs Issued by IRS for Non-Resident Taxpayers

Last year the IRS announced an alternative to its Offshore Voluntary Compliance Program (OVDP) which was being made available to a limited group of non-resident individuals who failed to file Foreign Bank Account Reports (FBARs) on Form TDF 90-22.1. Our tax lawyers blogged about the Streamlined Program previously, taking a…

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Foreign Bank Accounts and the Failure to File Foreign Bank Account Reports (FBARS) May Be the Death Knell of the 5th Amendment

The Fifth Circuit Court of Appeals ruled that offshore bank account records sought in a tax evasion. The IRS already knew based upon records it received from UBS that the witness held offshore bank accounts. To lay people, and even to most tax attorneys this was a startling result. Actually…

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IRS Foreign Bank Account Report (FBAR), TD F 90-22.1 FBAR Relief for Non-Residents With Offshore Bank Accounts–Too Little Too Late

Relief from penalties for failure to file Foreign Bank Account Reports (FBAR), TD F 90-22.1 for non-resident U.S. persons with offshore bank accounts was first announced by the IRS on June 26, 2012 with further guidance promised before the procedure’s September 1st effective date. On Friday Aug. 31, 2012 with…

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Criminal Tax Case Involving Offshore Bank Accounts Leads to Lawsuit Against U.S. Billionaire

When American billionaire Igor Olenicoff opened his offshore bank account with Swiss bank UBS, AG he was allegedly told he did not have to file Form TD F 90-22.1, or Foreign Bank and Financial Accounts Report, more commonly known as an FBAR, or pay taxes on the $180 million he…

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Offshore Bank Account Whistleblower Released from Prison

Former Swiss banker Bradley Birkenfeld has been released from prison where he had served 30 months of his 40-month sentence for his work at UBS, AG helping clients hide their offshore bank accounts. Mr. Birkenfeld exposed the Swiss bank as a facilitator for U.S. taxpayers who wished to commit tax…

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Denise Rich, Ex-wife of Marc Rich, Expatriates

Denise Rich, former wife of commodities trader Marc Rich who was indicted in the 1983 on charges of tax fraud, gave up her U.S. citizenship, avoiding potential future tax problems. The 68 year-old woman is a Grammy-nominated songwriter whose songs have been recorded by Aretha Franklin, Mary J. Blige and…

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IRS Provides Half-Baked Foreign Bank Account Report (FBAR) Relief for Some Offshore Account Holders Who Live Overseas

Some FBAR (Foreign Bank Account Report) relief was announced on June 26th for offshore account holders who currently live outside of the U.S. The program will not take effect until September 1st, and the details have not yet been finalized. Taxpayers who qualify will file delinquent returns for the past…

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Offshore Bank Account Owners at Liechtensteinische Landesbank AG (LLB) May be In Trouble

Lichtenstein tax authorities have notified Liechtensteinische Landesbank AG (LLB)’s U.S. clients with offshore accounts of at least $500,000 that their information is subject to being turned over to the IRS according to a report in Bloomberg.com. Apparently the IRS has made a so-called group request to LLB for these accounts…

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