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California Physician Pleads Guilty to Failing to File FBAR for Bank Leumi Account

On February 2, 2015, Baruch Fogel, a California doctor, pleaded guilty in the U.S. District Court for the Central District of California to one count of willful failure to report the existence of a foreign bank account on a...more

Bank Leumi Enters Into DPA with U.S. Department of Justice

A major Israeli international bank admitted that it conspired to aid and assist U.S. taxpayers to prepare and present false tax returns to the Internal Revenue Service (IRS) by hiding income and assets in offshore bank...more

Beanie Babies Creator Seeks Probation for $107 Million UBS Account

The Chicago Tribune reports that Beanie Babies creator Ty Warner, who pleaded guilty last year to one of the largest tax frauds in Chicago-area history, has asked the federal court to sentence him to probation. His sentencing...more

Voluntary Disclosures Lead to John Doe Summonses for Information about U.S. Accounts at Zurcher Kantonalbank and Bank of...

In a sign that the U.S. government continues to aggressively seek information on U.S. taxpayers with non-U.S. bank accounts, the government announced on November 12, 2013, that it had obtained a court order authorizing the...more

Voluntary Disclosure Program for Swiss Banks?

Bloomberg/BNA is reporting that the DOJ announced today a program for Swiss banks to reveal tax information in return for nonprosecution agreements. The U.S. Department of Justice announced a program Aug. 29 to get Swiss...more

Taxpayer Advocate Continues to Criticize Offshore Voluntary Disclosure Programs

In an update to her December 2012 report, the Taxpayer Advocate has noted that the IRS still has not provided reasonable options for “benign actors”, or taxpayers who inadvertently violated the rules for reporting foreign...more

Department of Justice Sues Taxpayer to Collect $3.5 Million in FBAR Penalties, Possibly Putting Dutch Bank ABN AMRO's Swiss...

Carl R. Zwerner of Miami, Florida, is facing nearly $3.5 million in civil penalties for failing to report a Swiss bank account, according to a lawsuit filed by the Justice Department (United States v. Zwerner, S.D. Fla., No....more

The 2012 FBAR Filing Deadline is June 30, 2013

U.S. taxpayers with foreign accounts whose aggregate value exceeded $10,000 at any time during 2012 must file Treasury Department Form TD F 90-22.1 (Report of Foreign Bank and Financial Accounts) with the Treasury Department...more

Government Runs Its Record to 4-0 in Compelling Production of Records of Offshore Bank Accounts

On February 7, 2013, the U.S. Court of Appeals for the Eleventh Circuit joined “the three of our sister circuits that have considered the same issue here about foreign financial account records and conclude that the...more

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