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Articles Posted in FBAR Violations

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FBAR Offshore Voluntary Disclosure Initiative (OVDI) Tax Amnesty Countdown

The last day for disclosing unfiled foreign bank account reports (FBARs) under the Offshore Voluntary Disclosure Initiative (OVDI) is August 31, 2011. OVDI FAQ No. 25 provides that the entire OVDI package must be submitted on or before August 31, 2011 to: Internal Revenue Service 3651 S. I H 35…

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Foreign Bank Account Report (FBAR) OVDI Deadline Extended–Sort of

Some articles, but not any tax attorneys we know, have suggested that the IRS has extended the 2011 Offshore Voluntary Disclosure Initiative (OVDI) for unfiled foreign bank account reports (FBARs) by 90 days. That’s not quite the case. The IRS has published FAQ 25.1 which provides that if an offshore…

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HSBC India Foreign Bank Account Client Indicted on FBAR (Foreign Bank Account) and False Tax Return Charges

The Department of Justice (DOJ) and Internal Revenue Service (IRS) announced last week the indictment of an HSBC India client on four counts of filing false tax returns and four counts of failure to file a Foreign Bank Account Report, form TD F 90-22.1 (FBAR). According to the press release…

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Foreign Bank Account Reporting Deadline Today

Holders of foreign bank accounts had until today June 30th, 2011, to file a foreign bank account report TDF 90-22.1 (FBAR) with the Internal Revenue Service (IRS). The IRS recently issued a press release reminding foreign bank account holders of FBAR reporting requirements and deadlines. The June 30th, 2011 FBAR…

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U.S. in Settlement Talks with Swiss Banks Holding Offshore Bank Accounts for U.S. Persons

Swiss Banks holding offshore bank accounts for U.S. residents may have a settlement deal in the works to avoid prosecution, according to Thompson Reuters. Under the terms of the reported deal, Swiss and European banks would avoid prosecution in exchange for paying a fine, exiting their undeclared offshore banking businesses…

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Foreign Bank Account Related Statute of Limitations

Many taxpayers who have FBAR (Foreign Bank Account Report) tax problems may be wondering about the statute of limitations or how long the IRS has to come after them. The FBAR civil penalty statute of limitations is six years from the date of the violation, generally June 30th. The criminal…

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FBAR OVDI FAQ Changes for Ex-Pats Are A Big Improvement

The IRS Offshore Voluntary Disclosure Initiative (OVDI) allowing non-filers of Foreign Bank Account Reports (FBARs) to fix their tax problems without fear of criminal tax prosecutions has been vastly improved for ex-patriate Americans. Americans who reside abroad can enter the OVDI program, and have their FBAR penalty limited to 5%…

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When a Swiss Banker or Tax Advisor Runs Afoul of the Internal Revenue Service, Tax Problems For His Clients Are Likely to Follow

As we reported recently on our Tax Problem Attorney Blog, the IRS crackdown on offshore bank accounts has led to more criminal tax charges against tax preparers and bankers. The U.S. Department of Justice recently accused Renzo Gadola, a former UBS banker, of encouraging a client not to report an…

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