News & Analysis as of

Department of Justice (DOJ) Foreign Bank Accounts

Freeman Law

Tax Court in Brief | Lamprecht v. Comm’r | Qualified Amended Return and Foreign Banking Reporting

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Tax Litigation:  The Week of August 29th, 2022, through September 2nd, 2022 Sparta Pink Property, LLC v. Comm’r, T.C. Memo. 2022-88 | August 29, 2022 | Lauber, J. | Dkt. No. 12114-20 Pressman v. Comm’r, T.C. Summ. Op....more

Freeman Law

Yet Another Streamlined Filing Turns into a Criminal Indictment, Implicating Former CPA and Businessman

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A recent IRS Criminal Investigation press release announced an indictment against a businessman charged with defrauding the United States by not disclosing offshore assets, failing to report income to the IRS, and submitting...more

Roetzel & Andress

IRS Asks Major Crypto Exchange For Users’ Identities And Data

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Earlier this month, the United States District Court, Northern District of California approved the Internal Revenue Service’s (IRS) request to execute a “John Doe” summons on the parent company of popular cryptocurrency...more

Ballard Spahr LLP

DOJ Indicts Professor and Drug Trafficking Expert for Laundering Proceeds of Venezuelan Corruption Scheme

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A Textbook Case of Alleged Money Laundering? On November 18, 2019, the U.S. Attorney for the Southern District of New York announced the arrest and unsealed the indictment of Bruce Bagley – a 73-year-old college professor...more

The Volkov Law Group

A Classic Criminal Investigation: Unraveling PDVSA Corruption

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The Justice Department has been criticized on numerous occasions about its approach to criminal investigations and prosecutions.  In a recent decision, the chief judge in the Eastern District of New York criticized DOJ for...more

Jones Day

First Conviction in the U.S. for FATCA Violations

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An investigation of Belize-based stockbrokers recently led to the first FATCA conviction since its enactment in 2010. The former head of an offshore bank pled guilty to conspiracy to defraud the United States by...more

Rosenberg Martin Greenberg LLP

What to Do (and Not Do) to Resolve Your Offshore Tax Issues

In recent months, the Internal Revenue Service (“the Service”) began the process of issuing follow-up letters to taxpayers who either requested preclearance to participate in the Offshore Voluntary Disclosure Program (“OVDP”)...more

Fox Rothschild LLP

Offshore Accountholders Beware: New DOJ Sentencing Policy For FBAR Cases Is A Game-Changer

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The Justice Department’s Tax Division has recently announced a major policy shift that will invariably result in longer jail sentences for individuals convicted of failing to report their offshore bank accounts on the FBAR...more

Mitchell, Williams, Selig, Gates & Woodyard,...

DOJ Announces Major New Shift in Criminal Sentencing in Offshore Tax Matters

At the 34th Annual National Institute on Criminal Tax Fraud in Las Vegas yesterday afternoon, Mark Daly, DOJ Tax Division Senior Litigation Counsel announced a major new shift in how the Department of Justice plans to argue...more

Fox Rothschild LLP

Justice Department’s Latest Offshore Bank Resolution Confirms Value Of Self-Disclosure And Voluntary Remediation By At-Risk...

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The Justice Department revealed its latest offshore bank resolution by announcing that it had entered into a non-prosecution agreement with a Swiss asset management firm called Prime Partners. This means that Prime Partners...more

Foodman CPAs & Advisors

¿Sabe usted por qué y cómo entrar en el Programa de Divulgación Voluntaria de Cuentas en el Extranjero (OVDP)?

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A través del Programa de Divulgación Voluntaria de Cuentas en el Extranjero (OVDP – Offshore Voluntary Disclosure Program), el IRS permite a los Contribuyentes que no están en cumplimiento intentionalmente revelar las cuentas...more

Foodman CPAs & Advisors

Do you know why and how to make an Offshore Voluntary Disclosure?

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Through its Offshore Voluntary Disclosure Program (OVDP), IRS permits noncompliant taxpayers to disclose Willfully unreported offshore accounts and related income. The “key” word for OVDP is Willful. Unlike the Streamlined...more

Williams Mullen

New Jersey Man Prosecuted for Funneling Campaign Contributions from Foreign Source

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Much of the U.S. media overlooked a Bill of Information filed in United States District Court in New Jersey on June 29. The information charged Bilal Shehu, an Albanian immigrant, with unlawfully funneling $80,000 from a...more

Pillsbury Winthrop Shaw Pittman LLP

Hong Kong & Singapore: Awaiting a New DOJ Tax Program for Asian Banks?

As the Department of Justice is wrapping up its prosecution of over a dozen Swiss banks, federal prosecutors and IRS special agents are analyzing a treasure trove of previously undeclared taxpayer account information that...more

Foley & Lardner LLP

IRS Seeks Identities of Americans with Undisclosed Belize Bank Accounts

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Americans with secret accounts in Belize should take notice: the government is looking for you. The U.S. Department of Justice on September 15 filed a petition in federal court in Miami seeking permission to issue summonses...more

Blank Rome LLP

IRS Targets a Belize Bank with a “John Doe” Summons

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The Internal Revenue Service will now obtain information on U.S. accountholders at a Belize bank – Belize Bank International Limited (“BBIL”) or Belize Bank Limited (“BBL”). Yesterday, the Justice Department announced that a...more

Thomas Fox - Compliance Evangelist

George Carlin and Erga Omnes: the Petrobras Bribery Scandal Expands

On this date in 2008 George Carlin died. If you grew up in the late 1960s or early 1970s and you had anti-parental or anti-establishment inklings, which of course all teenagers do, you knew about George Carlin. In the early...more

Blank Rome LLP

Two More Banks Reach Resolutions Under Justice Department’s Swiss Bank Program

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On June 3, 2015, the Justice Department announced that two more Swiss banks, Rothschild Bank AG and Banca Credinvest SA, reached resolutions under the DOJ Swiss Bank Program. Yesterday’s announcement brings the total Swiss...more

BakerHostetler

BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement

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Global tax enforcement is the number one priority of the U.S. authorities, and they are using their resources and tools in unprecedented ways to ensure that those who intentionally evade taxes are identified and brought to...more

Latham & Watkins LLP

Top 10 Foreign Bank Account Reporting (FBAR) Mistakes (And How to Fix Them)

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While FBAR reporting rules are frequently misunderstood, US persons have several options to correct mistakes, before the government learns of the non-compliance. June 30th is the annual deadline for filing a Foreign...more

Akerman LLP

DOJ Announces First Non-Prosecution Agreement Under the Swiss Bank Program

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On March 30, 2015, the U.S. Department of Justice (DOJ) announced that it reached the first non-prosecution agreement under the Swiss bank program with BSI, S.A. (BSI). BSI, one of Switzerland's ten largest banks, has agreed...more

Thomas Fox - Compliance Evangelist

Gulliver’s Travels, Truth or Fiction?

There was once a man named Gulliver who traveled widely and wrote a book about his adventures called Gulliver’s Tales. During his first voyage, Gulliver is washed ashore after a shipwreck and finds himself a prisoner of a...more

BakerHostetler

Bank Leumi Enters Into DPA with U.S. Department of Justice

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A major Israeli international bank admitted that it conspired to aid and assist U.S. taxpayers to prepare and present false tax returns to the Internal Revenue Service (IRS) by hiding income and assets in offshore bank...more

Blank Rome LLP

DOJ Continues to Prosecute Those Who Fail to File FBARs to Disclose Offshore Accounts

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Howard Bloomberg, a forensic account and certified fraud examiner of Atlanta, Georgia, pleaded guilty on Friday to failing to file a Foreign Bank Account Report (FBAR) for the year 2008. Mr. Bloomberg opened a bank account at...more

Pillsbury Winthrop Shaw Pittman LLP

DOJ Secures Verdict in Excess of $2 Million for Failure to File FBARs

On Wednesday, May 28, 2014, a jury in Miami issued a verdict against a taxpayer for $2.2 million in fees, interest, and civil penalties for willfully failing to file foreign bank account reports (FBARs) for his Swiss bank...more

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