Having spoken to hundreds of individuals who have offshore bank accounts, or who have clients with offshore bank accounts, or relatives with offshore bank accounts, or even a “friend” with an offshore bank account there are certain questions which continue to recur. I thought it would be helpful to answer…
Less than 10 shopping days before the Internal Revenue Service (IRS) Foreign Bank Account Report Tax Amnesty ends. September 23rd is the last day that owners of Swiss Bank Accounts, and other foreign financial accounts have to disclose their offshore holdings to the IRS Criminal Investigation Division in order to…
UBS has agreed to reveal the names and account information of 4,450 U.S. persons who are owners of UBS Swiss bank accounts who the Internal Revenue Service (IRS) believes have committed tax fraud. Clearly Swiss bank secrecy has more holes than Swiss cheese. The names will be revealed under the…
A Los Angeles, California man pled guilty to one count of failing to file a Foreign Bank Account Form TDF 90.22-1 (FBAR) pursuant to the Bank Secrecy Act 31 USC 5314. This is the fourth person with a UBS Swiss bank account to plead guilty to tax evasion charges. John…
On Wednesday, the UBS offshore tax evasion case moved one step closer to UBS disclosing the names of persons the IRS believes have committed tax fraud and/or failed to file TD F-90-22.1, Foreign Bank Account Report (FBAR). The IRS announced that it had “initialed a settlement” with the Swiss government…
Last week I blogged that UBS and the IRS had announced a preliminary settlement to the lawsuit seeking the names of 52,000 U.S. persons with Swiss bank accounts at UBS who the IRS suspects of tax evasion, and failing to file foreign bank account reports (FBARs). The failure to file…
On Friday it was announced that UBS and the Internal Revenue Service had reached a settlement in the IRS lawsuit against UBS. The lawsuit sought to require UBS to turn over the names of 52,000 U.S persons with Swiss bank accounts at UBS. The IRS believes that the owners of…
As pointed in my previous blog post the hearing in the IRS effort to enforce its John Doe Summons in the UBS Offshore Bank Account case had been delayed by mutual agreement with a status conference to be held on Wednesday, June 29th. According to an article by Tom Brown…
The past few months have been filled with contention from the Swiss government and UBS in response to the Internal Revenue Service’s (IRS) “John Doe Summons,” which seeks to have UBS turn over the names of their US account holders. So far, UBS has been unwilling to provide the names…
When the Internal Revenue Service (IRS) released its FBAR tax amnesty FAQs it stated that there would be no standard list of questions asked of foreign bank account holders who made a voluntary disclosure. The Wall Street Journal reported that at least one tax attorney has stated that his clients…