Lauryn Hill's Tax Evasion a 'Battle for Survival': Lawyer
On July 21, 2014 the OECD released the full version of a new global standard for the exchange of financial information in tax matters “OECD\Standard for Automatic Exchange of Financial Account Information in Tax Matters”...more
It has been just over five years since the Internal Revenue Service (“IRS”) offered the first of three offshore voluntary disclosure programs for individuals with undisclosed foreign financial accounts. Since the announcement...more
Since the 1970s, U.S. taxpayers with foreign banks accounts have been required to annually report their foreign bank account information to the Department of Treasury on a Report of Foreign Bank and Financial Accounts...more
Over the last several years, the Internal Revenue Service (IRS) has focused its efforts on enforcement of U.S. laws with respect to offshore assets held by U.S. citizens and residents, including their tax payment and...more
Former DOJ Tax Division AAG Kathy Keneally warned on June 24, 2014, that taxpayers should think carefully before signing a certification of non-willfulness and entering the IRS’s new Streamlined Filing Compliance Procedures....more
The annual deadline for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (commonly known as the “FBAR” form), is fast-approaching. Any U.S. taxpayer with a financial interest in, or signature or other...more
The changes give taxpayers who mistakenly failed to report foreign assets a simpler path back to tax compliance.
On June 18, 2014, the Internal Revenue Service (IRS) announced major modifications to the terms of its...more
Most United States persons who have foreign financial accounts are aware that they must file an annual report to the Internal Revenue Service (IRS) with respect to these accounts. Less well known, however, is that individuals...more
Several weeks ago, we reported that changes to the IRS’s Offshore Voluntary Disclosure Program (“OVDP”) were imminent and would focus on distinguishing between taxpayers who willfully violated their reporting requirements,...more
On Wednesday, the IRS announced substantial expansions of the 2012 Streamlined Filing Compliance Procedures and the 2012 Offshore Voluntary Disclosure Program (OVDP).
The IRS first designed the 2012 Streamlined Filing...more
On June 18, 2014 the Internal Revenue Service (“IRS”) announced a modification to the 2012 Offshore Voluntary Disclosure Program (“OVDP”). The 2014 OVDP is a continuation of the 2012 program with modified terms. The voluntary...more
In a recent appearance before THE U.S. Conference for International Business the IRS Commissioner stated the following:
“One of the most exciting aspects of our current times is to see governments working...more
On May 9, 2014, a Florida doctor was sentenced to serve two years in prison and three years supervised release for conspiring to defraud the Internal Revenue Service (IRS). The doctor was found guilty of concealing millions...more
The Internal Revenue Service (IRS) will have more leverage over those seeking to minimize their tax bills by moving assets outside the U.S. when the Foreign Account Tax Compliance Act (FATCA) takes effect on July 1, 2014....more
Since 2009, the Internal Revenue Service has offered three different amnesty programs for taxpayers with undeclared foreign bank accounts. These programs, the current version of which is entitled the Offshore Voluntary...more
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
According to the Miriam Webster dictionary, credibility is defined as "the quality or power of inspiring belief." When IRS Commissioner John Koskinen took office, one of his many roles involved trying to restore the integrity...more
In a jury verdict this wake in the Southern District of Florida, the IRS has a sharpened Sword of Damacles to hang over the head of FBAR reporting violators. In U.S. v. Zwerner, a jury found that Carl Zwerner WILLFULLY failed...more
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
In January of 2012 the Internal Revenue Service enacted the Offshore Voluntary Disclosure Program, or OVDP for short. This is actually the third recent version of the offshore voluntary disclosures. The voluntary disclosure...more
A Florida doctor was recently sentenced to multiple years in prison for income tax evasion. The taxpayer hid income and assets through the use of offshore bank accounts concealed by the use of offshore shell companies. This...more
On April 30, 2014, a federal grand jury in Los Angeles, California, indicted Shokrollah Baravarian for Klein conspiracy: conspiracy to defraud the United States by impairing and impeding the IRS.
If you have unreported income from offshore accounts, now may be the best time to come forward and report those earnings; otherwise, you may be susceptible to criminal prosecution.
The IRS initially began this...more
Today we conclude our review of recent sentences imposed in federal tax crime cases in 2014. In our two previous posts here and here, we reviewed sentences relating to Foreign Bank Account, Tax Evasion, Employment Tax, False...more
On Friday, we posted a review here of sentences imposed on defendants in 2014 for Foreign Bank Account, Tax Evasion, and Employment Tax crimes. In this post, we review sentences imposed on defendants in cases involving False...more
Back to Top