The failure to file a Foreign Bank Account Report TD F 90-22.1 (FBAR) for an offshore bank account has led to the seizure of an Alaska plastic surgeon’s $4.6 million dollar account at a Seattle branch of Bank of America. According to the complaint filed in District Court Alaska plastic…
Recently the Supreme Court held in Kawashima v. Holder (Feb. 21, 2012) that filing a false tax return in violation of IRC Section 7206(1) as well as other criminal tax offenses are aggravated felonies which can result in deportation of a resident alien. Just over two years ago we blogged…
In January I appeared on a panel with several other tax lawyers at the 2012 University of Southern California Tax Institute. One of the topics was Quick Tips on Offshore Bank and Financial Accounts. The presentation was intended for tax attorneys, CPAs, and other tax professionals. However, anyone who has…
In a little noticed development, Switzerland’s oldest private bank Clariden Leu has informed some of its U.S. clients that it has been ordered to turn over their names, and offshore bank account information to the IRS. Clariden Leu posted a notice on its website dated Nov. 29, 2011 to that…
According to press reports Credit Suisse, Basler Kantonalbank, Julius Baer, HSBC Switzerland and seven other Swiss banks are poised to turnover data related to U.S. persons suspected of tax evasion or Foreign Bank Account Reporting (FBAR) violations. The story was published on December 18th in SonntagsZeitung, a Swiss newspaper. Supposedly…
IRS Fact Sheet 2011-13 (FS -2011-13) has been heavily touted (mostly in the Canadian Press) as providing FBAR (Foreign Bank Account Report) relief for dual U.S. citizens abroad. However, in the view of our tax attorneys it simply reiterates existing law. As readers of the Tax Problem Attorney Blog are…
The Swiss Federal Tax Authority (SFTA) has ordered Credit Suisse to submit offshore bank account information in response to an IRS request for assistance, according to a New York Times article. Credit Suisse has notified some of its offshore account holders by letter about the order. Apparently the order is…
According to a report in the Swiss newspaper Tages-Anzeiger the Swiss are poised to send the names of thousands of potential tax evaders who have Swiss Bank accounts over to the IRS, and/or the Department of Justice. The data files are, according to the unconfirmed report, due to begin coming…
The IRS issued a news release on Sept. 15th headlined “IRS Shows Progress on International Tax Evasion.” IRS Commissioner Shulman was quoted as saying: “We have pierced international bank secrecy laws, and we are making a serious dent in offshore tax evasion.” Shulman noted that the IRS has increased its…
The Supervisor of Banks at the Bank of Israel and the supervisory authorities in the US–signed a Statement of Cooperation. The Statement of Cooperation establishes a mechanism for the transfer of information between the authorities in the context of the authorization process of establishing cross-border banking activity in the U.S.…