FBAR Conviction of NJ MD Affect Dual Nationals


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.

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Written by:


Law Offices of Sanford I. Millar on:

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