News & Analysis as of

Foreign Banks Offshore Funds

Rosenberg Martin Greenberg LLP

Offshore Update: IRS Releases Memorandum Addressing Updates to Voluntary Disclosure Practice After Closing Offshore Voluntary...

Now, More than Ever, Taxpayers with Lingering Offshore Tax Non-Compliance Must Seek Professional Assistance - On November 20, 2018, the Internal Revenue Service (“the Service”) released a memorandum containing important...more

Pillsbury Winthrop Shaw Pittman LLP

IRS Uses New Tactic to Expand Efforts to Combat Offshore Tax Evasion

In a search for financial records of a U.S. taxpayer who allegedly parked undeclared income offshore, the Internal Revenue Service (IRS) and the U.S. Department of Justice (DoJ) are seeking to enforce a summons against a U.S....more

BakerHostetler

American Pleads Guilty to Hiding Money in Swiss Bank, Moving Money to Israeli Bank after UBS Scandal

BakerHostetler on

On August 19, 2014, Bernard Kramer pleaded guilty in the Southern District of New York to conspiracy to defraud the United States and filing a false income tax return relating to his concealment of “at least $1.1 million” in...more

Blank Rome LLP

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

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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

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

Holland & Knight LLP

As Swiss Banking Becomes More Transparent, Americans with Undeclared Swiss Accounts Are Warned

Holland & Knight LLP on

In a move that was likely celebrated by United States governmental officials, Swiss banking secrecy eroded even further on Thursday, March 6, 2014. This is the day that parliament voted to provide foreign tax authorities with...more

Goodwin

Release of Names With Interests in Offshore Entities: Ramifications

Goodwin on

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

Holland & Knight LLP

FBAR Update

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The Report of Foreign Bank and Financial Accounts (FBAR) can no longer be filed on TDF 90-22.1, and must be e-filed on Form 114. This alert summarizes developments involving FBAR e-filing and signature authority. They are...more

BakerHostetler

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

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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

BakerHostetler

UBS Client Sentenced to One Year in Prison

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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

BakerHostetler

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

BakerHostetler on

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

BakerHostetler

New York Man Pleads Guilty to Hiding Inheritance in Swiss Account

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Tax Analysts Tax Notes is reporting that HENRY SEGGERMAN pled guilty today in Manhattan federal court to charges related to his participation in a scheme with family members to hide in secret Swiss bank accounts, and not...more

BakerHostetler

California Man Pleads Guilty to Hiding Money in Israeli Banks

BakerHostetler on

Tax Analysts Tax Notes is reporting that Aaron Cohen of Encino, Calif., pleaded guilty today in the U.S. District Court for the Central District of California to conspiracy to defraud the United States....more

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