Category Archives: OFFSHORE BANK ACCOUNTS

DOJ SETTLES WILLFUL FBAR PENALTY WITH HOLOCAUST SURVIVOR AFTER COURT DENIES ITS MOTION FOR SUMMARY JUDGMENT

Posted on November 8, 2023 by taxpenaltylawyer

The IRS had assessed a willful FBAR penalty against Walter Schik (Schik) in the amount of approximately $8.8 million for failure to timely file FinCEN Form 114 for the year 2007.  When Schik did not pay the assessed amount the … Continue reading →

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SOME COMMON MISCONCEPTIONS ABOUT THE STREAMLINED FILING COMPLIANCE PROCEDURES

Posted on September 29, 2017 by taxpenaltylawyer

I receive many inquiries about Streamlined Filings from U.S. citizens or Green Card holders living outside the U.S. as well as from recent immigrants to the U.S. or work visa holders living inside the U.S. In all of these cases, … Continue reading →

Posted in 2014 OVDP, AMENDED RETURNS, FBARS, OFFSHORE BANK ACCOUNTS, STREAMLINED FILING COMPLIANCE PROCEDURES, STREAMLINED FILINGS, Uncategorized | Tagged , , , , , | Leave a comment

THE CLOCK IS TICKING ON THE 27.5% OVDP OFFSHORE PENALTY (AS OPPOSED TO 50%) FOR THOSE WITH ACCOUNTS AT BANKS SOON TO BE ADDED TO THE IRS BAD BANKS LIST

Posted on May 30, 2015 by taxpenaltylawyer

The Department of Justice (DOJ) on May 29, 2015 announced that four more Swiss banks had entered into non-prosecution agreements (NPA), namely: Societe Generale Private Banking (Lugano-Svizzera) SA (effective 5/28/15) MediBank AG (effective 5/28/15) LBBW (Schweiz) AG (effective 5/28/15) Scobag … Continue reading →

Posted in 2014 OVDP, OFFSHORE BANK ACCOUNTS, OFFSHORE VOLUNTARY DISCLOSURE PROGRAM | Tagged , , , , | Leave a comment

IRS OFFICIALS ANSWER CIVIL AND CRIMINAL OFFSHORE QUESTIONS

Posted on February 26, 2015 by taxpenaltylawyer

On February 24, 2015 I participated in an ABA Tax Section Webinar, “Answering Your Criminal and Civil Offshore Disclosure Questions.”  On the Webinar panel were two IRS officials:  David W. Horton, Director, IRS International Individual Compliance; and John C. McDougal, … Continue reading →

Posted in 2014 OVDP, DELINQUENT RETURN, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, STREAMLINED FILING COMPLIANCE PROCEDURES, STREAMLINED FILING COMPLIANCE PROCEDURES, TAX, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , , , | 8 Comments

OFFSHORE VOLUNTARY DISCLOSURE PROGRAM (OVDP): STRICT APPLICATION OF 50% PENALTY CAN BE HARSH

Posted on February 15, 2015 by taxpenaltylawyer

Consider the following fact pattern: Father and daughter are participants in the OVDP who submitted their OVDP Letters after August 4, 2014.   Each owned separate unreported offshore bank accounts during the OVDP period 2006 through 2013. The father’s account was … Continue reading →

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IRS UNRELENTING IN PURSUIT OF UNREPORTED OFFSHORE ACCOUNTS

Posted on January 28, 2015 by taxpenaltylawyer

Today the IRS released IR-2015-9, “Hiding Money or Income Offshore Among the “Dirty Dozen” List of Tax Scams for the 2015 Filing Season” which provides verbatim: WASHINGTON — The Internal Revenue Service today said avoiding taxes by hiding money or … Continue reading →

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EVALUATING RISK OF PROSECUTION OUTSIDE OF THE OVDP

Posted on December 10, 2014 by taxpenaltylawyer

An article authored by Edward Robbins, Jr. Steven Toscher and Dennis Perez, “What’s Your Client’s Criminal Exposure on His Undeclared Foreign Bank Account? (Journal of Tax Practice, October – November 2012 pp 67-74), astutely summarizes the most likely charged tax … Continue reading →

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THERE’S NOTHING CIVIL ABOUT THE STREAMLINED FILING PROCESS

Posted on December 2, 2014 by taxpenaltylawyer

Many believe that you can bifurcate the Streamlined Process between the criminal aspect and civil aspect.  That once you have a non-willful opinion from the criminal tax lawyer, the process becomes civil and any competent civil tax lawyer or tax … Continue reading →

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SOME CLARIFICATION FROM IRS ON THE STREAMLINED FILING COMPLIANCE PROCEDURES.AND DEINQUENT INTERNATIONAL INFORMATION RETURN SUBMISSIONS.

Posted on November 9, 2014 by taxpenaltylawyer

The IRS has updated its Streamlined Filing Compliance Procedures and Delinquent International Information Return pages (October 9, 2014) and issued Frequently Asked Questions with regard to each. The FAQs for U.S. Taxpayers residing in the U.S. clarify that: The 5% … Continue reading →

Posted in 214 OVDP, COMPLIANCE, FBARS, OFFSHORE BANK ACCOUNTS, TAX | Tagged , , , , , , , , | 1 Comment