Four Swiss bankers have been charged with conspiracy to defraud the United States of income tax revenue, according to an indictment unsealed in the United States District Court in Virginia. The bankers are accused of helping high net worth clients hide undeclared Swiss bank accounts. U.S. citizens with $10,000 or…
On Tuesday the IRS announced a new tax amnesty for owners of foreign bank accounts who failed to file FBARs (Foreign Bank Account Reports). The new voluntary disclosure program is known as the Offshore Voluntary Disclosure Initiative (OVDI). The IRS has issued its FAQ for the Offshore Voluntary Disclosure Initiative…
Two former executives of an investment firm were sentenced to more than 4 months in prison after authorities convicted them of a tax fraud scam that fabricated stock losses in order to help wealthy clients avoid taxes. The U.S. Attorney’s Office for the Western District of Washington reports the firm…
The IRS is expected to launch a new offshore bank account tax amnesty very soon announced Steven Miller, IRS Deputy Commissioner for services and enforcement. He made the announcement at an American Bar Association Tax Section Meeting in Boca Raton, Florida. The program which is sometimes referred to as the…
Our tax attorneys noted a recent case in which a woman is accused of hiding $750,000 in an offshore bank account set up by her father with Swiss banking giant UBS AG. Too often people think Swiss bank account problems only impact the very wealthy. In fact, they impact those…
Rudolph Elmer, an ex Julius Baer executive turned over offshore bank account information to WikiLeaks today, according to Bloomberg News. According to the release, data on 2000 offshore bank accounts has been turned over, and WikiLeaks plans on making the data public; although it says it will take at least…
Since March of 2009 about 18,000 owners of offshore bank accounts have filed voluntary disclosures with the IRS. So what does FATCA mean to current holders of overseas financial accounts who have not filed FBARs (Foreign Bank Account Reports) on Form TDF 90.22-1, and who have not taken advantage of…
FATCA (Foreign Account Tax Compliance Act of 2009) could be one of the final nails in the coffin for offshore banks referred to as foreign financial institutions or FFIs. When I first heard about FATCA after it was passed in March of 2010 I didn’t pay much attention. After all…
In mid-October the IRS filed a summary judgment motion seeking FBAR (Foreign Bank Account Report, Form TDF 90-22.1) penalties of over $225,000 for a civil failure to file an FBAR. This is only the second civil FBAR case that I am aware of which didn’t involve an underlying non-tax crime.…
Last month the IRS lost a case (United States v. J. Brian Williams) in which it tried to impose the 50% penalty for willfully failing to file a Foreign Bank Account Report, TD F 90-22.1 (FBAR). This appears to be the first case that has gone to court on FBAR…