International Law & Trade, Tax Law, Criminal Law

The Offshore Voluntary Disclosure Program: A Brief History And Overview Of The Complexities Involved In Disclosing Foreign Assets

by CMCP - California Minority Counsel Program on 5/22/2013

The IRS and the Justice Department have increased their efforts regarding criminal investigation of international tax evasion. ...more

International Tax Compliance Update: Florida Couple Indicted for Failing to Report Offshore Bank Accounts as IRS Continues...

by Fuerst Ittleman David & Joseph, PL on 5/22/2013

In line with our recent coverage of the Internal Revenue Service’s initiatives to pursue illegal offshore tax havens, on May 16, 2013 a Florida couple – Drs. David Leon Fredrick and Patricia Lynn Hough – was indicted by a...more

Indian American Neurosurgeon Sentenced to Probation for Unreported Offshore Bank Accounts

by Jay Nanavati | BakerHostetler on 5/21/2013

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

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

by Jay Nanavati | BakerHostetler on 5/21/2013

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

Tax Compliance Update: IRS Aggressively Pursues Foreign Banks; Offshore Voluntary Disclosure Program to Remain Open Indefinitely

by Fuerst Ittleman David & Joseph, PL on 5/15/2013

In our most recent discussion of the IRS’s Offshore Enforcement Initiatives, we discussed the John Doe Summons recently issued by the U.S. Department of Justice to Wells Fargo seeking information about First Caribbean...more

IRS Announces Information Sharing Agreement With Australia And The UK To Combat Tax Evasion

by David Gair | Looper Reed & McGraw, P.C. on 5/13/2013

The IRS continues to aggressively pursue offshore tax evasion. Another example of which is plan to share tax information with Australia and the United Kingdom....more

IRS Issues “John Doe Summons” to Wells Fargo Seeking Identities of U.S. Taxpayers with Offshore Accounts at First Caribbean...

by Fuerst Ittleman David & Joseph, PL on 5/9/2013

Introduction - On April 30, 2013, the United States Department of Justice issued a “John Doe Internal Revenue Code” summons to Wells Fargo Bank, as a provider of correspondent bank services for Canadian Imperial Bank...more

OVDI Pre-Clearance Letters And Their Revocability

by Charles (Chuck) Rubin on 5/8/2013

The first step a taxpayer with undisclosed or unreported offshore accounts or assets undertakes in seeking to enter the Offshore Voluntary Disclosure Initiative (OVDI) is to apply for pre-clearance from the IRS Criminal...more

Grand Jury Indicts Swiss Lawyer and Banker in Tax Evasion Scheme

by Tenley Mochizuki, Emily Stern | Katten Muchin Rosenman LLP on 5/1/2013

A New York federal grand jury recently indicted a Swiss lawyer and bank executive for their roles in allegedly assisting US citizens with hiding assets in Swiss bank accounts, allowing the US citizens to evade income taxes....more

Bank Leumi Snafu Jeopardizes DOJ-IRS Offshore Enforcement Initiatives

by Jeremy Temkin | Morvillo Abramowitz Grand Iason & Anello P.C.... on 5/1/2013

Three times over the past four years, the IRS has given taxpayers with undisclosed offshore accounts the opportunity to come clean and avoid prosecution. While the most recent offer – the 2012 Offshore Voluntary Disclosure...more

Unusual Results In Offshore Account Case

by Charles (Chuck) Rubin on 4/29/2013

79 year-old Mary Estelle Curran received good new when she was sentenced for criminal tax evasion and failing to file reports of foreign bank accounts on UBS Swiss accounts she inherited from her husband....more

Reasonable Cause Explained

by Sanford Millar on 4/22/2013

Taxpayer’s often find themselves facing substantial penalties for failing to file or late payment of income estate or gift tax return. Some taxpayers face enormous penalties for failing to file a Report of Foreign Bank or...more

OVDP or 50% FBAR Willfulness Penalty; It is Your Choice

by Sanford Millar on 4/15/2013

The Criminal Tax Division of the U.S. Dept of Justice (DOJ)is taking the position that when a taxpayer has “willfully” failed to file a Report of Foreign Bank or Financial Account, an FBAR, and has in addition filed false...more

Argentina Seeks Access to Financial Information on Nationals

by Rebecca Leon | Morgan Lewis on 4/1/2013

Argentina signs the OECD Convention, but it does not obtain automatic access to financial information. On September 13, 2012, the Organization for Economic Co-operation and Development (OECD) announced that Argentina...more

The 50% FBAR Penalty, Are you at Risk?

by Sanford Millar on 4/1/2013

June 30 is the deadline for U.S. taxpayers, (including resident aliens) to timely report foreign financial accounts for the year ending 2012. The report form (TD 90-22.1) known as an FBAR is due if a U.S. taxpayer has control...more

US Court Orders Wegelin to Pay a Total Penalty of $74 Million

by Fuerst Ittleman David & Joseph, PL on 3/14/2013

As has been widely reported, the United States District Court for the Southern District of New York sentenced Wegelin & Co, the oldest Swiss private bank, to pay an additional $58 million after it admitted to helping wealthy...more

Third Circuit Court of Appeals Affirms Tax Court Decision on CARDS Tax Shelter

by Fuerst Ittleman David & Joseph, PL on 3/13/2013

On February 25, 2013, the United States Court of Appeals for the Third Circuit in the case of Crispin v. Commissioner, ___ F.3d ___, 2013 U.S. App. LEXIS 3852 (3d Cir. 2013), available here, affirmed the decision of the Tax...more

DOJ Revokes Some Pre-Clearances for Bank Leumi Depositors

by Sanford Millar on 3/11/2013

A recent press release should send a shudder to some voluntary disclosure participants. It should frighten some tax preparers and their clients....more

FATCA And Voluntary Disclosure

by Michael Volkov on 3/7/2013

The Internal Revenue Service has had success encouraging taxpayers with offshore accounts to disclose their foreign accounts and pay back taxes. In 2009 and 2011, the IRS announced the Offshore Voluntary Disclosure Program...more

Offshore Banks, Required Records and Secret Funds Transfers: a Receipe for Disaster

by Sanford Millar on 2/25/2013

Recently, two Israeli banks are reported to have agreed to cooperate in criminal tax investigations being conducted by the Criminal Tax Division of the U.S. Department of Justice. The specific actions allegedly involve a...more

Final FATCA Rules Issued by U.S. Treasury Deparment: Future Impact Still Being Considered, But It Will Be Huge for International...

by Rosa Eckstein Schechter on 1/25/2013

This week, the Treasury Department released the Final Rules for FATCA -- the agency regulations that work to implement and enforce the Foreign Account Tax Compliance Act...more

Must You Produce Records of Offshore Accounts?

by Sanford Millar on 1/21/2013

A Petition to the U.S.Supreme Court may result in the Court deciding whether a taxpayer who has a previously unreported foreign financial account must produce records of the account in a criminal proceeding in spite of the...more

New Jersey Businessman With NRI Account Pleads Guilty to Using Offshore Bank Accounts to Defraud the U.S. and Pays $2.37 Million...

by Jay Nanavati | BakerHostetler on 1/15/2013

Sanjay Sethi, a New Jersey businessman, pleaded guilty on January 7, 2013 to using hidden offshore bank accounts to defraud the U.S. in a so-called “Klein conspiracy.”...more

IRS Announces Revised FATCA Implementation Timelines

by Richard J. Horne, Christina M. Iafe, Brian Silikovitz | Lowenstein Sandler LLP on 11/29/2012

The Foreign Account Tax Compliance Act (“FATCA”) was enacted in 2010 as part of an effort to combat tax evasion by U.S. taxpayers holding investments in offshore accounts and through offshore intermediaries. FATCA creates a...more

District Court Decides FBAR Penalty Assessment Case - Both A Win For The Government & For OVDP Participants

by Moskowitz LLP on 11/26/2012

Here at Moskowitz LLP, A Tax Law Firm based in San Francisco, CA, we have been following just how the Internal Revenue Service will collect FBAR penalties once imposed outside the scope of any Offshore Amnesty Program. ...more

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International Law & Trade › Tax Law › Criminal Law