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…
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…
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…
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%…
The IRS has filed a foreign bank account holders who may have committed failed to file an FBAR with the IRS, and who also failed to report their income from these accounts. The John Doe summons is similar to the one filed on Swiss banking giant UBS, AG in 2008…
Last month I was quoted in a Tax Analysts article by Amy Hamilton on the lack of a California offshore voluntary disclosure program. The FTB responded that there was something in the works. As if owners of offshore bank accounts didn’t have enough in the way of tax problems, on…
The United States Tax Court has upheld the tax evasion. In December 2005, David W. Goldston was sentenced to 48 months in prison and three years’ supervised release. He was also ordered to cooperate with the IRS in determining outstanding taxes, interests and penalties. He didn’t, and ultimately his case…
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…
Tax attorneys continue to deal with the fallout from increased offshore enforcement by the IRS. The U.S. Justice Department announced this month that a San Diego resident was sentenced to three years probation after he was found to have filed false tax returns from 2000 to 2008. The case involved…
Tax lawyers representing a man accused of failing to file business income tax returns told the judge that obsessive-compulsive disorder was responsible for their client’s tax problems, the Calgary Herald reported. Business tax debt can sink a business; frequent issues tax attorneys are called to deal with include payroll tax…