Category Archives: 2012 OVDP

SOME SWISS BANKS ARE MORE THAN ENCOURAGING U.S. CLIENTS TO ENTER THE OVDP – THEY ARE OFFERING FINANCIAL INCENTIVES

Posted on July 21, 2014 by taxpenaltylawyer

An article in the Wall Street Journal on July 19, 2014 by John Letzing (“Taxpayers Get Incentives to Report: Swiss Banks Aim to Entice Americans to Disclose Accounts to IRS by Helping Cover Costs, Penalties”), reveals what many professionals have … Continue reading →

Posted in 2012 OVDP, 214 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, TAX CRIMES, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , | 1 Comment

IRS CRIMINAL INVESTIGATION DIVISION OFFICIALS PARTICIPATING IN ABA TAX SECTION WEBINAR INDICATE THAT OFFSHORE TAX FRAUD WILL CONTINUE TO BE EMPHASIZED BY CID

Posted on July 8, 2014 by taxpenaltylawyer

On July 8, 21014 Edward Cronin, Associate Chief Counsel (Criminal Tax) and Don Fort, CID Director of Field Operations participated in an ABA Tax Section Webinar, “Current IRS Criminal Investigation Enforcement Priorities and Issues.”  Some of the highlights from the … Continue reading →

Posted in 2012 OVDP, 214 OVDP, FBARS, NEW OVDP, TAX, TAX CRIMES, VOLUNTARY DISCLOSURE | Leave a comment

STILL HAVE AN UNREPORTED FORIEGN FINANCIAL ACCOUNT? BEWARE THE TRUSTED ADVISORS: THEY WILL GIVE YOU UP TO SAVE THEIR OWN SKINS

Posted on July 6, 2014 by taxpenaltylawyer

The DOJ Press Release reproduced below in its entirety should be very scary to those still out in the cold with unreported foreign financial accounts.  We know that foreign banks are taking steps to minimize their risk of criminal prosecution … Continue reading →

Posted in 2012 OVDP, 214 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX CRIMES, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , , | 2 Comments

SOME ADVANTAGES AND DISADVANTAGES OF STREAMLINED PROCEDURES FOR U.S. CITIZENS AND RESIDENTS RESIDING IN THE U.S.

Posted on June 30, 2014 by taxpenaltylawyer

“Beware of false knowledge; it is more dangerous than ignorance.” – George Bernard Shaw Shaw’s admonition is applicable to the recently announced Streamlined Process and Transitional as alternatives for resolving offshore noncompliance exposure of U.S. citizens and residents.  Calls I’ve … Continue reading →

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OFFSHORE TAXPAYERS WITH ACCOUNTS AT IRS LISTED BANKS NEED TO ACT NOW

Posted on June 21, 2014 by taxpenaltylawyer

Revised FAQ 7.2, for the Offshore Voluntary Disclosure Program, provides:  What if the government is investigating the foreign financial institution where I hold my account or another facilitator who assisted in establishing or maintaining my offshore arrangement?  Beginning on August … Continue reading →

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INITIAL THOUGHTS ON IRS CHANGES TO OFFSHORE VOLUNTARY DISCLOSURE PROGRAM AND STREAMLINED PROCESS FOR NON-WILLFUL TAXPAYERS

Posted on June 19, 2014 by taxpenaltylawyer

Yesterday, June 18, 2014, IRS announced and posted to the Offshore Voluntary Disclosure page on its website (www.irs.gov) significant changes to the 2012 OVDP reflected in revised Frequently Asked Questions; and, new Streamlined Filing Compliance Procedures for non-willful, out-of-compliance taxpayers, whether … Continue reading →

Posted in 2012 OVDP, COMPLIANCE, FBARS, NEW OVDP, TAX, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , | 11 Comments

ON FBAR WILLUL NON-FILING AND WILLFUL BLINDNESS – THE RUMSFELD DISCLAIMER

Posted on April 23, 2014 by taxpenaltylawyer

In United States v. Williams, (2012), the Fourth Circuit Court of Appeals reversed the District Court’s holding that Williams’ failure to file an FBAR that was due June 30, 2001 was a non-willful failure to file because the government already … Continue reading →

Posted in 2012 OVDP, FBARS, JOINT RETURNS, NEW OVDP, OFFSHORE BANK ACCOUNTS, POLICY, RETURNS, TAX | Tagged , , , , , , , , | Leave a comment

106 SWISS BANKS AGREE TO NAME NAMES OF US DEPOSITORS

Posted on February 7, 2014 by taxpenaltylawyer

My post of September 6, 2013, “Heat on Offshore Tax Evaders Turned up: DOJ Offers Swiss Government Sanctioned Deal to Smaller Swiss Banks,” described in some detail the Swiss Bank Settlement Program (SBSP) under which Swiss banks not already under … Continue reading →

Posted in 2012 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, VOLUNTARY DISCLOSURE | Tagged , , , , , | Leave a comment

THE OFFSHORE DOMINOES ARE TUMBLING DOWN AND CREDIT SWISS WILL SOON FOLD

Posted on January 24, 2014 by taxpenaltylawyer

The Wall Street Journal reported today (“Credit Swiss Nears Tax-Cheat Deal,” by John Letzing, Francesco Guerrera and David Enrich) ) that Credit Swiss, Switzerland’s second largest bank, is said to be in serious negotiations with the Department of Justice to … Continue reading →

Posted in 2012 OVDP, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, VOLUNTARY DISCLOSURE | Tagged , , , , , , | Leave a comment

IT’S GOOD TO BE RICH: BEANIE BABY FOUNDER GOES FREE

Posted on January 17, 2014 by taxpenaltylawyer

Part T of the Federal Sentencing Guidelines Manual deals with “Offenses Involving Taxation.” The Introductory Commentary states: The criminal tax laws are designed to protect the public interest in preserving the integrity of the nation’s tax system.  Criminal tax prosecutions … Continue reading →

Posted in 2011 OVDI, 2012 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, TAX CRIMES, VOLUNTARY DISCLOSURE | Tagged , , , , , , | Leave a comment