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Category Archives: VOLUNTARY DISCLOSURE
IRS OFFICIALS ANSWER CIVIL AND CRIMINAL OFFSHORE QUESTIONS
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
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Tagged AMENDED RETURNS, FBAR, FBAR PENALTIES, FOREIGN BANK ACCOUNTS, IRS STREAMLINED FILING COMPLIANCE PROCEDURES, NEW STREAMLINED PROCESS FOR OFFSHORE ACCOUNTS, OFFSHORE BANK ACCOUNTS, OFFSHORE TAX FRAUD, OVDP, QUIET DISCLOSURES, REASONABLE CAUSE, ROBERT S STIENBERG, SWISS BANK SETTLEMENT PROGRAM, VOLUNTARY DISCLOSURE, WILLFULNESS
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IRS UNRELENTING IN PURSUIT OF UNREPORTED OFFSHORE ACCOUNTS
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 →
EVALUATING RISK OF PROSECUTION OUTSIDE OF THE OVDP
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 →
Posted in 214 OVDP, FBARS, OFFSHORE BANK ACCOUNTS, TAX, VOLUNTARY DISCLOSURE
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Tagged BANK SECRECY ACT, FBAR PENALTIES, FOREIGN BANK ACCOUNTS, IRS STREAMLINED FILING COMPLIANCE PROCEDURES, OVDP, OVDP BENEFITS, QUIET DISCLOSURES, RISK OF PROSECUTION IN OFFSHORE CASE, ROBERT S STIENBERG, TAX CRIMES, VOLUNTARY DISCLOSURE, WILLFULNESS
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THERE’S NOTHING CIVIL ABOUT THE STREAMLINED FILING PROCESS
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 →
Posted in 214 OVDP, FBARS, OFFSHORE BANK ACCOUNTS, TAX, VOLUNTARY DISCLOSURE
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Tagged ESQ., IRS STREAMLINED FILING COMPLIANCE PROCEDURES, NEW STREAMLINE FILING PROCESS, NEW STREAMLINED PROCESS FOR OFFSHORE ACCOUNTS, RISKS INS STREAMLINED PROCESS, Robert S. Steinberg, WHO SHOULD ASSIST WITH STREAMLINED FILING?
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SOME SWISS BANKS ARE MORE THAN ENCOURAGING U.S. CLIENTS TO ENTER THE OVDP – THEY ARE OFFERING FINANCIAL INCENTIVES
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
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Tagged 2012 OVDP, BANK SECRECY ACT, FBAR, FBAR PENALTIES, FOREIGN BANK ACCOUNTS, OFFSHORE ACCOUNTS, OFFSHORE TAX FRAUD, OVDP, ROBERT S STIENBERG, SWISS BANK FINANCIAL INCENTIVES, SWISS BANK SETTLEMENT PROGRAM, TAX CRIMES, VOLUNTARY DISCLOSURE
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THE TAX LAW IS COMPLEX; OFFSHORE COMPLIANCE DECISIONS ARE DIFFICULT AND MISTAKES CAN HAVE GRAVE CONSEQUENCES
John J. Scroggin published an interesting and entertaining survey of tax complexity in the Wealth Strategies Journal (Tax Complexity, History, and Humor, July 8, 2014). The article begins with a quote from Judge Learned Hand: “In my own case the … Continue reading →
Posted in 214 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, VOLUNTARY DISCLOSURE
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Tagged COMPEXITY OF OVDP DECISIONS, FBAR, FBAR PENALTIES, FOREIGN BANK ACCOUNTS, OFFSHORE ACCOUNTS, OFFSHORE BANK ACCOUNTS, OFFSHORE TAX FRAUD, OVDP, OVDP BENEFITS, OVDP OPT OUT, QUIET DISCLOSURES, Robert S. Steinberg, TAX COMPLEXITY
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SOME ADVANTAGES AND DISADVANTAGES OF STREAMLINED COMPLIANCE PROCEDURES FOR U.S. EXPATS
“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 permanent residents who … Continue reading →
Posted in 214 OVDP, FBARS, OFFSHORE BANK ACCOUNTS, TAX, TAX CRIMES, UNFILED RETURNS, VOLUNTARY DISCLOSURE
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Tagged EXPATS AND UNFILED FBARS, FBAR PENALTY, Robert S. Steinberg, STREAMLINED COMPLIANCE PROCEDURES FOR EXPATS, STREAMLINED PROCESS OF THOSE LIVING OUTSIDE U.S., US CITIZENS LIVING ABROAD
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IRS CRIMINAL INVESTIGATION DIVISION OFFICIALS PARTICIPATING IN ABA TAX SECTION WEBINAR INDICATE THAT OFFSHORE TAX FRAUD WILL CONTINUE TO BE EMPHASIZED BY CID
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
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STILL HAVE AN UNREPORTED FORIEGN FINANCIAL ACCOUNT? BEWARE THE TRUSTED ADVISORS: THEY WILL GIVE YOU UP TO SAVE THEIR OWN SKINS
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
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Tagged 2012 OVDP, BANK SECRECY ACT, FBAR, FBAR PENALTIES, FOREIGN BANK ACCOUNTS, OFFSHORE ACCOUNTS, OFFSHORE BANK ACCOUNTS, OFFSHORE TAX FRAUD, OVDP, OVDP BENEFITS, ROBERT S STIENBERG, SWISS BANKS, TAX CRIMES, VOLUNTARY DISCLOSURE
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IRS COMMENTS ON NEW STREAMLINED FILING PROCEDURES FOR NON-WILLFUL OFFSHORE TAXPAYERS
Amy S. Elliott’s article, IRS Answers Questions on Updated OVDP and Streamlined Filing, 2014 TNT 120-9 (6/23/14) summarizes selected comments of IRS officials at NYU’s recent Tax Controversy Forum. Two IRS officials were present: Jennifer Best, senior adviser, IRS Large … Continue reading →
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