News & Analysis as of

Senate Hearing Takes Aim on Offshore Tax Evasion

Today, February 26, 2014, the Senate Permanent Subcommittee on Investigations will hold a hearing on offshore tax evasion titled “Offshore Tax Evasion: The Effort to Collect Unpaid Taxes on Billions in Hidden Offshore...more

6 Reasons US Taxpayers Should Report Assets Held in Swiss Banks Soon

Initial success of DOJ Swiss bank amnesty program creates greater urgency for US taxpayers. On December 31, 2013, the window to apply for the US Department of Justice’s (DOJ) amnesty program closed for certain Swiss...more

Release of Names With Interests in Offshore Entities: Ramifications

A database containing the names of more than 37,000 people with offshore entities and trusts in 10 tax haven jurisdictions was recently released online, providing a powerful investigative tool for regulators, journalists and...more

FBAR E-Filing and Signature Authority: What You Need to Know

Much has been written about the IRS's dogged pursuit of taxpayers with unreported foreign accounts. These accounts are reported on the Report of Foreign Bank and Financial Accounts (FBAR) when a taxpayer has a financial...more

Federal Court Rejects Efforts to Diminish Measures Aimed at Reducing Offshore Tax Avoidance

As of January 1, 2013, United States banks were required to report to the IRS interest earned by nonresident aliens who are residents of certain foreign countries. The reporting requirement previously existed for accounts...more

Implications of the Foreign Account Tax Compliance Act, FATCA

Protecting domestic revenue is just one of several reasons why G-20 nations are cracking down on tax havens. Other reasons include their desire to track the international flow of funds used for terrorist activity or money...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

More Swiss Banks Will Disclose/Cooperate with Offshore Tax Investigations

The U.S. Department of Justice (DOJ) offer of non-prosecution agreements to certain Swiss banks expires December 31, 2013. Swiss banks who know or suspect that they have violated U.S. law, but who are not currently the...more

American Pleads Guilty to Hiding Money in Israeli Bank Accounts

Tax Analysts Tax Notes is reporting that David Raminfard of Los Angeles pleaded guilty on November 4, 2013, in federal court to one count of conspiracy to defraud the United States (Klein conspiracy). ...more

District Court Rules for Taxpayer in STARS Case Santander Holdings; Court of Federal Claims Rules for Government in STARS Case...

In this issue: - Swiss Bank Settlement Dilemma - District Court Upholds STARS Transaction Ruling Payment Is Included in Pre-Tax Profit - Court of Federal Claims Holds for Government in BB&T STARS...more

Arizona Businessmen Receive Lenient Sentences For Stashing Millions in Secret Swiss Accounts

Bloomberg BNA is reporting that two prominent Phoenix businessmen were each sentenced to 10 months in prison for their roles in a scheme to stash more than $8 million in secret offshore Swiss bank accounts and for not...more

Swiss Banks to Receive No Credit for Customers Who Entered OVDP without Banks' Encouragement

Tax Analysts Tax Notes reports that Kathryn Keneally, assistant attorney general for the Justice Department Tax Division, said that Swiss banks that enter the IRS’s newly-offered program will receive no credit for customers...more

The DOJ Ratchets Up Its Crackdown On Swiss Bank Accounts

In my last post, I discussed the possibility that Bitcoins and other virtual currencies could replace Swiss bank accounts as the tax havens of the future. Recent developments in the government’s war on offshore accounts...more

UBS Client Sentenced to One Year in Prison

Bloomberg reports that a client of UBS AG was sentenced to a year and a day in prison for using a Swiss bank account to evade more than $1 million in taxes. ...more

Beanie Babies Creator to Plead Guilty to Hiding Income in Swiss Account

Tax Analysts reports that H. Ty Warner, owner of Beanie Babies production company TY Inc., was charged yesterday with federal tax evasion for allegedly failing to report on his 2002 Form 1040 more than $3.1 million in gross...more

Required Records, The Act Of Production And Secret Offshore Accounts

The Fifth Amendment dictates that no person "shall be compelled in any criminal case to be a witness against himself." While most non-lawyers (and many lawyers) might assume that this simple edict means the government cannot...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

17 Results
|
View per page
Page: of 1