News & Analysis as of

Tax Evasion Bank Secrecy Act Foreign Bank Account Report

Lerch, Early & Brewer

Tenth Circuit Affirms Deficiencies, Penalties for Offshore Income

Lerch, Early & Brewer on

Harrington v. Commissioner - In Harrington v. Commissioner of Internal Revenue, George S. Harrington (Harrington) challenged tax deficiencies and fraud penalties assessed for tax years 2005 through 2010. Originally...more

Cole Schotz

Important Supreme Court Decision will Decide how Non-Willful FBAR Penalties are Calculated

Cole Schotz on

This fall, the Supreme Court is set to hear an important case regarding the interpretation of the law that provides for penalties for failing to file an FBAR. The case will impact many taxpayers who have already been...more

Ballard Spahr LLP

Manafort Indictment Alleges High-End International Money Laundering and Tax Fraud Involving Offshore Accounts

Ballard Spahr LLP on

As the world now knows, an indictment against Paul Manafort, Jr., a former campaign chairperson for now-President Donald Trump, and Manafort’s associate, Richard Gates III, was unsealed yesterday. ...more

Blank Rome LLP

FBAR Penalty to Face Excessive Fines Clause Test

Blank Rome LLP on

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

CMCP - California Minority Counsel Program

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

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