Tax Evasion Bank Secrecy Act

News & Analysis as of

FBAR Penalty to Face Excessive Fines Clause Test

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

Leavers are targets of Offshore Tax Enforcement

Leavers are those U.S. taxpayers who have undeclared offshore financial accounts and who move those accounts from one bank to another, often moving to other countries in the hope of avoiding disclosure of the account to U.S....more

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

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

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

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

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