Read Tax Law news, alerts, and legal commentary from leading lawyers and law firms:
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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
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
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
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
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
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
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
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
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 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
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
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
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
A recent press release should send a shudder to some voluntary disclosure participants. It should frighten some tax preparers and their clients....more
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
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
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
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
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
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
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
For many years, the Internal Revenue Service ("IRS") has had a "voluntary disclosure" policy in its Criminal Manual. Under the policy, a disclosure preliminarily accepted by the Criminal Investigation Division (CI) is...more
While tens of thousands of taxpayers have entered the offshore voluntary disclosure process many more have not. The reasons for not filing voluntary disclosures are not important, what is important is what happens if a...more
One of the questions that taxpayers in the Offshore Voluntary Disclosure programs ask is should I “opt out” of the program if the penalty is unacceptable to me. The question often arises in the context of value of assets...more
One of the major issues that confront taxpayers when deciding to enter the Offshore Voluntary Disclosure Program (OVDP) is why do so if I may only “opt out” later. The main reason to enter the program is to limit exposure to...more
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