The FBAR indictments just keep coming. The Department of Justice announced April 15th the filing of charges against seven individuals who collectively hid more than $100 million from the IRS by using sham companies to conceal their ownership of secret Swiss bank accounts held at UBS AG.
The defendants are variously charged with conspiracy, tax fraud, criminal tax offenses, and/or willful failure to file a Foreign Bank Account Report, Form TDF 90-22.1 (FBAR). Those defendants charged with willful failure to file FBARs may be subject to a civil penalty of up to 50 percent of the value of the accounts for each year the accounts were not disclosed.
Two defendants, Jules Robbins and Federico Hernandez, pleaded guilty to separate criminal charges and agreed to pay civil penalties of $20.8 million and $4.4 million, respectively.
Two additional defendants surrendered on the 15th, one is expected to surrender on the 19th, and two others remain at large.
It’s apparent the IRS purposely chose today to announce these new indictments. IRS Criminal Investigation Chief Victor S.O. Song stated, “Today is the deadline to file a U.S. tax return, and those Americans who file accurate, honest and timely returns can be assured that the government will hold accountable those who don’t. For those still hiding in this shadowy world of secret offshore accounts, it is time to come in and get right with your government or face stiff criminal and financial penalties.”
If you’d like information about making a voluntary disclosure of your offshore bank accounts, contact the tax lawyers at Brager Tax Law Group, A P.C.