FBAR Conviction of NJ MD Affect Dual Nationals

Explore:  OVDP

On January 11, 2012 Michael Reiss, a physician from NJ was sentenced for failing to report offshore (Swiss) bank accounts(11:CR:0068),United States District Court SDNY. The sentencing memos of the U.S make some important policy statements.

The policy statements are:

First, Dr. Reiss made no effort to enter the IRS Voluntary Disclosure Program (OVDP) which began in 2009.

Implication: Taxpayer’s should make every effort to come forward on their own. Taxpayer’s should now come forward if they have not already.

Second, Reiss was aware of his obligation to file a Report of Foreign Bank Account (FBAR) as he filed reports annually on certain offshore accounts, but not the Swiss accounts.

Implication: This is a badge of willful behavior and the 50% FBAR penalty will be sought in similar circumstances.

Please see full article below for more information.

LOADING PDF: If there are any problems, click here to download the file.

Written by:

Published In:


DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Sanford Millar, Law Offices of Sanford I. Millar | Attorney Advertising

Don't miss a thing! Build a custom news brief:

Read fresh new writing on compliance, cybersecurity, Dodd-Frank, whistleblowers, social media, hiring & firing, patent reform, the NLRB, Obamacare, the SEC…

…or whatever matters the most to you. Follow authors, firms, and topics on JD Supra.

Create your news brief now - it's free and easy »

All the intelligence you need, in one easy email:

Great! Your first step to building an email digest of JD Supra authors and topics. Log in with LinkedIn so we can start sending your digest...

Sign up for your custom alerts now, using LinkedIn ›

* With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name.