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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