Tag Archives: BANK SECRECY ACT

CAUTION: IRS MAY ALREADY HAVE YOUR NAME OR WILL SOON. OFFSHORE DRAGNET LEADS UNNAMED FOREIGN BANKS TO COOPERATE

Posted on November 8, 2013 by steinbergtaxlaw

Some still out in the cold with offshore financial accounts take comfort in the fact that their bank has not yet been indicted or named in any publicly announced IRS investigation.  Well, here is some sobering news to shake confidence … Continue reading →

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THE WRONG QUESTION TO ASK ABOUT OFFSHORE ACCOUNTS: WHAT ARE THE ODDS OF BEING CAUGHT?

Posted on October 25, 2013 by steinbergtaxlaw

In my post of July 14, 2013, “OVDP or Nothing At All,” I wrote: I believe the wiser approach for most is still to seek the shelter of certainty by entering the OVDP  (IRS 2012 OFFSHORE VOLUNTARY DISCLOSURE PROGRAM). I … Continue reading →

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E-FILING OF FBARS NOW MANDATORY

Posted on August 5, 2013 by steinbergtaxlaw

The Financial Crimes Enforcement Network (FinCEN) has issued its Final Notice requiring the electronic filing of most Bank Secrecy Act (BSA) reports by July 1, 2012. The mandated reports filed by financial institutions include: Suspicious Activity Reports (SARs) filed by … Continue reading →

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OVDP OR NOTHING AT ALL

Posted on July 14, 2013 by steinbergtaxlaw

The 1939 song, “All or Nothing at All,” (by Arthur Altman and Jack Lawrence) made popular by Frank Sinatra might be sung in a new version by IRS, “OVDP or Nothing at All.” The Bank Secrecy Act contains draconian penalties … Continue reading →

Posted in 2012 OVDP, AMENDED RETURNS, DELINQUENT RETURN, FBARS, NEW OVDP, TAX, TAX CRIMES, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , | Leave a comment

OFFSHORE PROBES EXPAND BEYOND SWITZERLAND: NOMINEE ENTITY FAILS TO SHIELD TRUE ACCOUNT OWNER

Posted on May 5, 2013 by steinbergtaxlaw

Two recent guilty pleas in a California District Court, announced in April by the DOJ, should shake what complacency remains for those with unreported offshore accounts outside of Switzerland.  The IRS can find you even if your account is in … Continue reading →

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IRS TO GET MORE EASY PICKINGS OF OFFSHORE FRUIT

Posted on March 23, 2013 by steinbergtaxlaw

Two high level IRS Criminal Investigation (CI) officials participated an American Bar Association, Tax Section, Webinar, “Criminal Tax Enforcement Hot Topics: The IRS Perspective,” (March 20, 2013).  Edward “Ted” Cronin is the Division Counsel/ Associates Chief Counsel (Criminal Tax) … Continue reading →

Posted in 2012 OVDP, AMENDED RETURNS, COMPLIANCE, DELINQUENT RETURN, FBARS, NEW OVDP, TAX, TAX CRIMES, TAX INFORMATION EXCHANGE AGREEMENTS, UNFILED RETURNS, VOLUNTARY DISCLOSURE | Tagged , , , , , , , | Leave a comment

HIGH NOON IS DRAWING NEARER FOR THOSE STILL OUT IN THE COLD WITH UNREPORTED OFFSHORE ACCOUNTS

Posted on November 27, 2012 by steinbergtaxlaw

In director Fred Zinnemann’s iconic western, “High Noon,” (1952), Will Kane (Gary Cooper) is the retiring lawman in a small town. On the day of his wedding to Ana Fowler (Grace Kelley) he learns that Frank Miller whom he’d sent … Continue reading →

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COMPELLED TO SELF-INCRIMINATE: EROSION OF THE FIFTH AMENDMENT’S PROTECTION FOR PERSONAL FOREIGN BANKING RECORDS REQUIRED TO BE KEPT UNDER BANK SECRECY ACT REGULATIONS

Posted on September 30, 2012 by steinbergtaxlaw

Many legal scholars on both sides of the Obamacare debate have voiced concern about Chief Justice Roberts’ opinion in the Supreme Court’s decision on the Patient Protection and Affordable Care Act, specifically upholding the Act based on Congress’ power to … Continue reading →

Posted in FBARS, TAX, TAX CRIMES, Uncategorized, UNFILED RETURNS, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , , , , | Leave a comment