News & Analysis as of

Significant Setbacks to U.S. War on Offshore Tax Evasion with Two Not Guilty Verdicts for Offshore Bankers

As reported in this blog and elsewhere over the past few weeks, Raoul Weil was on trial in Florida for conspiring with U.S. taxpayers to hide their assets from the IRS through secret accounts held at UBS AG. Weil was the...more

Orwell’s 1984 30 Year Later

Welcome to 1984 30 years later! One of the most famous quotes from George Orwell’s 1984 is “Big Brother is Watching You.”. This quote is more true now than at any time in past. At the just concluded Global Forum on Tax...more

Treasury and IRS Issue Inversion Notice

The Treasury Department and the IRS released Notice 2014-52 (the “Notice”) on September 22nd to limit expatriation transactions. The Notice states that Treasury will issue regulations intended to limit the tax benefits of...more

IRS Updates to the Streamlined Compliance Procedures under the Offshore Voluntary Disclosure Program: New Forms Standardize the...

On June 18, 2014, the IRS announced sweeping changes to the 2012 Offshore Voluntary Disclosure Program (OVDP). Since that time, additional clarification on procedural requirements has been issued. Most recently, as of August...more

Forget About Hiding Money Offshore!

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

Can an OVDP Participant Set Aside a Closing Agreement on the Theory of Duress?

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

Offshore Tax Enforcement Update: IRS Unveils Major Changes to Voluntary Disclosure Program

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

IRS Broadens Offshore Amnesty Program

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 Head of DOJ Tax Division Warns Taxpayers to Think Twice Before Choosing New Streamlined Procedures

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

Offshore Tax Enforcement Update: Foreign Bank Account Disclosure Deadline Is June 2014

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

IRS Eases Access to Offshore Voluntary Disclosure Programs

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

IRS Identifies ‘Attorneys-in-Fact’ as Potentially Required to File Under the Foreign Bank Account Reporting Rules

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

International Tax Compliance Update: Offshore Voluntary Disclosure Program Modifications: A Trap for the Unwary

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

IRS Continues Pursuit of Undisclosed and Unreported Financial Accounts - Important New Developments

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

Updated Roadmap To IRS’ 2014 Offshore Voluntary Disclosure Program For Taxpayers With Undisclosed Offshore Accounts

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

IRS Offshore Enforcement Update

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

Florida Doctor Sentenced for Defrauding the IRS

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

Tax Evasion Gets Harder as FATCA Goes into Effect July 1

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

IRS Commissioner Hints That OVDP Modifications Are in the Works

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

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

IRS Unveils New Compliance Program

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

IRS Sharpens Its Sword Of Damacles

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

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

Roadmap To IRS' Offshore Voluntary Disclosure

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

DOJ Waging War Against Offshore Shell Companies

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

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