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Tax Problem Attorney Blog

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Swiss Banks to Turn Over Possible Tax Evaders to IRS

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…

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IRS Touts Progress on International Tax Evasion

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…

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Tax Lawyer Convicted of Aiding and Abetting Tax Evasion

A “tax attorney’s” conviction for aiding and abetting tax fraud I am not sure that makes him a tax attorney). The District Court sentenced the attorney to 30 months in prison and 3 years of supervised release. While this seems like a light sentence don’t forget that the tax attorney’s…

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Lack of Funds Not a Defense to Criminal Tax Fraud Charges

Criminal tax charges were recently upheld by the Sixth Circuit Court of Appeals against an individual who withheld payroll taxes but failed to pay those amounts over to the Internal Revenue Service (“IRS”). The defendant had been convicted of fifteen counts of Failure to Account for and Pay Over Withholding…

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More Tax Problems for U.S. Citizens with Foreign Bank Accounts in Israel

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.…

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OPR (Office of Professional Responsibility) Disbars a CPA, and an Enrolled Agent under Circular 230 for Failure to File Tax Returns

The IRS Office of Professional Responsibility (OPR) alleged that Joseph Kozelsky did not file timely tax returns for 2001 through 2007 and did not timely pay his federal tax liability. As a result of his tax problems he was disbarred from practice before the Internal Revenue Service. Mr. Kozelsky didn’t…

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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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