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Global Tax Enforcement in 2015: What You Need to Know

Tax fraud occurs on a considerable scale that can exceed law enforcement’s ability to detect and punish the conduct. This is true at both the federal and state levels. As of 2015, the Internal Revenue Service (“IRS”) and the...more

New York Restaurateur Pleads Guilty to Hiding Money in Swiss Accounts

On February 19, 2015, Georges Briguet, the owner of New York restaurant Le Perigord, pleaded guilty to one count of corruptly endeavoring to obstruct the IRS by concealing the existence of his Swiss bank accounts. According...more

2/23/2015  /  IRS , Offshore Funds , Tax Evasion

Bank Leumi Enters Into DPA with U.S. Department of Justice

A major Israeli international bank admitted that it conspired to aid and assist U.S. taxpayers to prepare and present false tax returns to the Internal Revenue Service (IRS) by hiding income and assets in offshore bank...more

American Pleads Guilty to Hiding Money in Swiss Bank, Moving Money to Israeli Bank after UBS Scandal

On August 19, 2014, Bernard Kramer pleaded guilty in the Southern District of New York to conspiracy to defraud the United States and filing a false income tax return relating to his concealment of “at least $1.1 million” in...more

Swiss Financial Institution Pays $4.4 Million and Turns Over 110 Americans

Bloomberg BNA reported on May 9, 2014, that Swisspartners Group resolved a U.S. criminal tax probe by forfeiting $3.5 million and paying $900,000 in restitution for helping U.S. clients evade taxes with secret accounts. ...more

Fugitive Swiss Banker Returns to U.S. and Enters Guilty Plea

On April 30, 2014, Josef Dorig, 72, of Switzerland, pleaded guilty in federal district court in Alexandria, Virginia, to a single count of Klein conspiracy: conspiracy to defraud the U.S. by impairing and impeding the IRS....more

IRS Official Announces Crackdown on U.S. Taxpayers with Unreported Indian Accounts

Tax Analysts Tax Notes reports that the IRS Small Business/Self-Employed Division's special enforcement program (SEP) will soon begin examining U.S. taxpayers suspected of holding undeclared accounts in Indian banks. An IRS...more

11/15/2013  /  India , IRS , Offshore Funds , Tax Evasion

Swiss Banks to Receive No Credit for Customers Who Entered OVDP without Banks' Encouragement

Tax Analysts Tax Notes reports that Kathryn Keneally, assistant attorney general for the Justice Department Tax Division, said that Swiss banks that enter the IRS’s newly-offered program will receive no credit for customers...more

UBS Client Sentenced to One Year in Prison

Bloomberg reports that a client of UBS AG was sentenced to a year and a day in prison for using a Swiss bank account to evade more than $1 million in taxes. ...more

Beanie Babies Creator to Plead Guilty to Hiding Income in Swiss Account

Tax Analysts reports that H. Ty Warner, owner of Beanie Babies production company TY Inc., was charged yesterday with federal tax evasion for allegedly failing to report on his 2002 Form 1040 more than $3.1 million in gross...more

New York Man Pleads Guilty to Hiding Inheritance in Swiss Account

Tax Analysts Tax Notes is reporting that HENRY SEGGERMAN pled guilty today in Manhattan federal court to charges related to his participation in a scheme with family members to hide in secret Swiss bank accounts, and not...more

California Man Pleads Guilty to Hiding Money in Israeli Banks

Tax Analysts Tax Notes is reporting that Aaron Cohen of Encino, Calif., pleaded guilty today in the U.S. District Court for the Central District of California to conspiracy to defraud the United States....more

Taxpayer Advocate Continues to Criticize Offshore Voluntary Disclosure Programs

In an update to her December 2012 report, the Taxpayer Advocate has noted that the IRS still has not provided reasonable options for “benign actors”, or taxpayers who inadvertently violated the rules for reporting foreign...more

IRS Rules that Mexican Fideicomisos or Land Trusts are not Trusts for U.S. Tax Purposes

On June 6, 2013, the IRS released Revenue Ruling 2013-14, which holds that Mexican fideicomisos or Land Trusts are not trusts for U.S. tax purposes. “Fideicomisos have been an issue in the offshore disclosure world for quite...more

Indian American Neurosurgeon Sentenced to Probation for Unreported Offshore Bank Accounts

On February 1, 2013, the U.S. District Court for the Eastern District of Wisconsin sentenced Arvind Ahuja, a Milwaukee neurosurgeon, to serve three years of probation and to pay a fine of $350,000 following his conviction by...more

Government Runs Its Record to 4-0 in Compelling Production of Records of Offshore Bank Accounts

On February 7, 2013, the U.S. Court of Appeals for the Eleventh Circuit joined “the three of our sister circuits that have considered the same issue here about foreign financial account records and conclude that the...more

Supreme Court Settles Fifth Amendment Required Records Issue in Context of Offshore Bank Accounts

On May 13, 2013, the Supreme Court denied a taxpayer’s petition for certiorari regarding the Seventh Circuit’s August 27, 2012, decision applying the Required Records Exception to override the taxpayer’s Fifth Amendment...more

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