The hearing on the tax fraud through the use of tax fraud. Generally, under the terms of the existing treaty with Switzerland, the IRS must have evidence of tax evasion before the Swiss will turn over Swiss bank accounts at UBS. According to offshore financial account must report that TD…
The Swiss government has threatened to seize UBS summons lawsuit pending in District Court in Miami, Florida. Does this mean that U.S. taxpayers who have tax fraud or John Doe summons case there are numerous other ways it can come to the attention of the IRS. For example, most offshore…
I have been speaking a lot lately to the Internal Revenue Service’s (IRS) tax amnesty hotline to obtain answers to the many practical questions that have arisen under the IRS Tax Amnesty a.k.a. tax amnesty program take place?” The agent that I spoke with at the tax audits will be…
The IRS has just issued new FAQs related to the Foreign Bank Account Reports (FBAR). There are 21 new offshore financial account penalty as part of the FBAR prior post. If the taxpayer disagrees with the imposition of the penalties then the taxpayer may go to the IRS Appeals Division.…
The U.S. Treasury has announced an agreement with Switzerland to amend the Swiss U.S tax treaty to allow the U.S. to more easily locate those engaged in tax fraud and tax evasion. The Swiss – U.S. treaty would be amended to comply with Article 26 of the Organization for Economic…
In an address to the Organization for Economic Co-Operation and Development (OECD) on June 2, 2009, IRS Commissioner Douglas Shulman announced renewed IRS efforts to combat international tax fraud and tax evasion. Shulman promised to create an inhospitable climate for tax evasion and offshore secrecy by continuing and expanding cooperation…
In May, the IRS Office of Professional Responsibility (OPR) issued penalty guidelines, sometimes referred to as a “penalty grid” for imposing penalties on tax preparers, and others who are tax attorneys, CPAs, or enrolled agents who fail to file timely income tax returns. The late filing of an income or…
In conversations with the IRS Foreign Bank Account Report (FBAR) hotline, I have been told that the IRS plans on issuing a second FBAR FAQ to supplement the first FBAR FAQ which was issued by the IRS only last month. As readers of this blog know, the first FBAR FAQ…
Frank L. Amodeo has serious criminal tax problems. The U.S. Department of Justice announced that he has been convicted in one of the biggest employment tax fraud cases in Internal Revenue Service (IRS) history. The penalties for these criminal tax charges exceed 22 years and he will be required to…
I have been and will be speaking to several CPA firms as well as various California CPA Society groups regarding the tax problems that have been generated by the failure to file Foreign Bank Account Reports (FBARs), TD 90-22.1, and a possible solution through the Internal Revenue Service’s voluntary disclosure…