FBAR

The Offshore Voluntary Disclosure Program: A Brief History And Overview Of The Complexities Involved In Disclosing Foreign Assets

by CMCP - California Minority Counsel Program on 5/22/2013

The IRS and the Justice Department have increased their efforts regarding criminal investigation of international tax evasion. ...more

Indian American Neurosurgeon Sentenced to Probation for Unreported Offshore Bank Accounts

by Jay Nanavati | BakerHostetler on 5/21/2013

On February 1, 2013, the U.S. District Court for the Eastern District of Wisconsin sentenced Arvind Ahuja, a Milwaukee neurosurgeon, to serve three years of probation and to pay a fine of $350,000 following his conviction by...more

Government Runs Its Record to 4-0 in Compelling Production of Records of Offshore Bank Accounts

by Jay Nanavati | BakerHostetler on 5/21/2013

On February 7, 2013, the U.S. Court of Appeals for the Eleventh Circuit joined “the three of our sister circuits that have considered the same issue here about foreign financial account records and conclude that the...more

FBAR Penalties and Estate Administration

by Sanford Millar on 5/20/2013

The death or disability of a taxpayer who has failed to timely file a Report of Foreign Bank or Financial Account (FBAR) can present difficult problems for fiduciaries like trustees, estate executors and conservators. The...more

FBAR Filing Due for Foreign Financial Account Holders

by Michael Cho | Berkeley Research Group, LLC on 5/18/2013

The 2012 Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), is due June 30, 2013. An employee or officer who has signature or other authority over, or financial interest in, foreign financial accounts is...more

IRS Announces Information Sharing Agreement With Australia And The UK To Combat Tax Evasion

by David Gair | Looper Reed & McGraw, P.C. on 5/13/2013

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

IRS Issues “John Doe Summons” to Wells Fargo Seeking Identities of U.S. Taxpayers with Offshore Accounts at First Caribbean...

by Fuerst Ittleman David & Joseph, PL on 5/9/2013

Introduction - 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

EB-5 Visas Applicant Need Tax Opinions

by Sanford Millar on 4/29/2013

An EB-5 Visa is known as an “investor” visa. The following is an explanation of the EB-5 program...more

Reasonable Cause Explained

by Sanford Millar on 4/22/2013

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

OVDP or 50% FBAR Willfulness Penalty; It is Your Choice

by Sanford Millar on 4/15/2013

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

2013 Mutual Funds and Investment Management Conference

by Ropes & Gray LLP on 4/10/2013

In this presentation: - General Counsel’s Address - Keynote Address - General Session — It’s a Small World After All: How Non-U.S. Regulators Affect Your Business - General Session — Closer to...more

The 50% FBAR Penalty, Are you at Risk?

by Sanford Millar on 4/1/2013

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

Eleventh Circuit Holds that Production of Foreign Bank Account Records May be Compelled in Criminal Investigation Under Required...

by Nicholas J. Nastasi, Matthew Smith | Saul Ewing LLP on 3/25/2013

The Eleventh Circuit recently joined the Fifth, Seventh, and Ninth Circuits in holding that subpoenaed foreign financial records properly fall within the Required Records Exception to the Fifth Amendment privilege against...more

FinCEN Proposes Third-Party Filing Of FBAR Reports

by BuckleySandler LLP on 3/14/2013

On Mach 5, FinCEN published a notice and request for comment on proposed changes to the Foreign Bank and Financial Accounts Report (FBAR) to standardize it with other BSA electronically filed reports and allow for a third...more

DOJ Revokes Some Pre-Clearances for Bank Leumi Depositors

by Sanford Millar on 3/11/2013

A recent press release should send a shudder to some voluntary disclosure participants. It should frighten some tax preparers and their clients....more

Eleventh Circuit Court of Appeals Sustains Required Records Exception to the Fifth Amendment

by Fuerst Ittleman David & Joseph, PL on 3/1/2013

On February 7, 2013, the U.S. Court of Appeals for the Eleventh Circuit affirmed the decision of the U.S. District Court for the Northern District of Georgia holding that the Required Records Exception overrides a...more

Offshore Banks, Required Records and Secret Funds Transfers: a Receipe for Disaster

by Sanford Millar on 2/25/2013

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

Non-FBAR Penalites and Offshore Voluntary Disclosures

by Sanford Millar on 2/18/2013

The following summarizes in explicit detail why taxpayers who have an unfilled Report of Foreign Financial or Bank Account (FBAR) must consider entering the Offshore Voluntary Disclosure Program (OVDP). Not only does the...more

FBAR Penalties and the Reasonable Cause Defense

by Sanford Millar on 2/11/2013

Some taxpayer’s who think that they have properly relied on the advice of professionals and should therefore be able to avoid FBAR penalties need to consider what constitutes “reasonable cause”. First, the reasonable cause...more

Tax Traps Accompany EB-5 Visas

by Sanford Millar on 2/11/2013

EB-5 Visas are sought after investment based pathways to a Green card. An EB-5 Visa is described in Wikipedia as follows...more

Must You Produce Records of Offshore Accounts?

by Sanford Millar on 1/21/2013

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

New Jersey Businessman With NRI Account Pleads Guilty to Using Offshore Bank Accounts to Defraud the U.S. and Pays $2.37 Million...

by Jay Nanavati | BakerHostetler on 1/15/2013

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

FBAR Filing Deadline Further Extended to June 30, 2014 for Certain Employees and Officers with Signature Authority Over Foreign...

by Ropes & Gray LLP on 1/14/2013

Generally, each U.S. person who has a financial interest in, or signature authority over, one or more foreign financial accounts during a calendar year is required to report those accounts to the Internal Revenue Service...more

FinCEN Extends FBAR Filing Deadline

by BuckleySandler LLP on 1/9/2013

On December 26, FinCEN issued Notice 2012-2 to extend the deadline for certain filers to submit the Report of Foreign Bank and Financial Accounts (FBAR). FinCEN has extended this deadline several times in the past and the...more

FinCEN Announces Third Extension for Certain FBAR Filers

by Richard LaFalce, Charles Lubar, Gabriel Quihuis, Richard Zarin, William P. Zimmerman | Morgan Lewis on 1/7/2013

Certain individuals having only signature authority over foreign financial accounts now have until June 30, 2014, to file the Report of Foreign Bank and Financial Accounts. ...more

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