Foreign Bank Accounts

News & Analysis as of

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

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

Highlights of Final Regulations for Reporting of Specified Foreign Financial Assets

The Treasury Department has issued final regulations relating to reporting of specified foreign financial assets on Form 8938. The highlights include...more

New Cyprus decrees further relax banking restrictions

The Republic of Cyprus issued new decrees on 8 December 2014. The new decrees provide further relaxation to banking restrictions, notably: Payments and/or transfers of funds abroad up to €2.000.000 (previously...more

FATCA Update: Treasury Clarifies Obligations of Participating FFIs to Report Pre-Existing Accounts

Earlier today, Treasury and the IRS issued yet another correcting amendment to the previously-issued regulations implementing the Foreign Account Tax Compliance Act (FATCA). FATCA become effective on July 1, 2014, and...more

Wegelin & Co. Account Holder Sentenced to Prison Term

On October 30, 2014, a federal judge in Manhattan handed down a three-month prison sentence to an individual who maintained more than $1 million in a secret bank account at Wegelin & Co. in Switzerland. Viktor Kordash, of...more

Government of India Discloses Names of Overseas Bank Account Holders: Risk and Ramifications Analysis

The Government of India (GOI) on 27 October 2014 made a disclosure to the Supreme Court of India containing the names of three prominent individuals who had opened overseas bank accounts allegedly with proceeds tainted...more

At Her Majesty‘s Pleasure? Directors of ‘can pay, won‘t pay’ award debtors face the prospect of an extended stay in England should...

The grant by Males J of an order for the appointment of receivers by way of equitable execution in relation to foreign assets held by two arbitration award debtors, Unitech Limited (”Unitech”) and Burley Holdings Limited...more

FATCA Notebook: Former IRS Chief, Taxpayer Advocate Criticize FATCA; Switzerland Moves Toward Greater Transparency

First, former acting IRS Commissioner Steven Miller speaks out against FATCA and suggests that the benefits of the new information reporting regime imposed by FATCA may not outweigh its costs. An article published by...more

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

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

IRS Issues FATCA Fraud Alert

As part of its continuing efforts to combat the serious problem of identity theft, the Internal Revenue Service warned today that fraudsters have expanded their widening schemes to obtain identity information to foreign...more

What Financial Advisers and Accountants Should Know About Expanded IRS Streamlined Filing Compliance Procedures for U.S. Taxpayers...

The Internal Revenue Service (IRS) recently announced “major changes” to its offshore compliance programs, including the Streamlined Filing Compliance Procedures (Streamlined Procedures), the delinquent international...more

Bitcoin Reportability and Taxation

June 30 is the deadline for taxpayers with a connection to foreign financial accounts to file FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR). As this is the first year in which all FBARs must be...more

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

Latest Cyprus decrees relaxing restrictive measures in banking

The Republic of Cyprus issued new decrees on 2 June 2014 which provide further relaxation of restrictive measures, including abolishing restrictions on the opening of new bank accounts. ...more

Will the Zwerner FBAR Fine Pass Constitutional Muster?

Last week, a federal jury in Miami found that Carl Zwerner had willfully failed to disclose his foreign bank account to the Treasury Department for calendar years 2004, 2005 and 2006. Zwerner now potentially owes the United...more

Swiss Bank Pleads Guilty In Alleged Tax Evasion Conspiracy

On May 19, the DOJ announced that a Swiss bank pleaded guilty and entered into agreements with federal and state regulators to resolve a multi-year investigation into the bank’s alleged conspiracy to assist U.S. taxpayers in...more

Getting a Green Card Subjects Noncitizens to U.S. Foreign Bank Account Reporting Requirements

A resident or citizen of a country other than the United States who obtains lawful permanent resident status in the United States, often referred to as a “green card,” becomes a resident of the United States for U.S. income...more

Court Rules U.S. Banks Must Disclose Nonresident Bank Account Information

As a result of a court decision last week, issued by the District Court in the District of Columbia U.S banks will be required to report interest earned on accounts held be non-resident aliens if the interest earned is $10.00...more

Beanie Babies Creator Seeks Probation for $107 Million UBS Account

The Chicago Tribune reports that Beanie Babies creator Ty Warner, who pleaded guilty last year to one of the largest tax frauds in Chicago-area history, has asked the federal court to sentence him to probation. His sentencing...more

Guide to the British Virgin Islands Approved Manager Regime

This guide provides an overview of the British Virgin Islands’ Approved Manager regime. The regime came into effect on 10 December 2012 with the Investment Business (Approved Managers) Regulations, 2012 (the “Regulations”)...more

Raminfard Guilty Plea Highlights Complexity Of International Tax Compliance, Seriousness Of Violations, Importance Of IRS Offshore...

Los Angeles Businessman, David Raminfard, pleaded guilty on November 4th, 2013 in the Federal District Court in Los Angeles to conspiring to defraud the United States, the Justice Department and Internal Revenue...more

International Tax News - November 2013

US-SWISS VOLUNTARY DISCLOSURE PROGRAM: DEADLINES ARE LOOMING – SWISS BANKS NEED NOT PANIC, BUT MUST ACT SWIFTLY AND THOUGHTFULLY - The recently announced voluntary bank disclosure program between Switzerland and the...more

Voluntary Disclosures Lead to John Doe Summonses for Information about U.S. Accounts at Zurcher Kantonalbank and Bank of...

In a sign that the U.S. government continues to aggressively seek information on U.S. taxpayers with non-U.S. bank accounts, the government announced on November 12, 2013, that it had obtained a court order authorizing the...more

US Allows Swiss Banks With Undisclosed Accounts To Wipe the Slate Clean

United States Department of Justice issues further information on amnesty program for Swiss banks, including details on the selection of an Independent Examiner. On November 5, 2013, United States Department of Justice...more

U.S. Department of Justice Awaits Swiss Banks’ Voluntary Disclosure of Banking Activities

The U.S. Department of Justice (“DOJ”) established a Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (the “Program”) on August 29, 2013. The Program is intended to facilitate a resolution with the...more

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