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Tag Archives: FBARS
OVDP TO END ON SEPT. 28, 2018 – ACT NOW ON UNDISCLOSED OFFSHORE ACCOUNTS
I don’t often post verbatim complete IRS pronouncements. This post is an exception, however, because the IRS Newswire Issue reprinted below contains an urgent message for those with unreported offshore income and / or foreign financial accounts who have not … Continue reading →
DEPARTMENT OF JUSTICE AND IRS CONTINUE TO FOCUS ON CATCHING OFFSHORE TAX CHEATS
The Department of Justice Tax Division on August 17 released a transcript of comments made by Principal Deputy Assistant Attorney General, Caroline D. Ciraolo, who had spoken at the Panama Bankers Association Anti-Money-Laundering Conference.in Panama City, Panama. Some take-aways from … Continue reading →
Posted in 2014 OVDP, STREAMLINED FILING COMPLIANCE PROCEDURES, Uncategorized
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Tagged DIVORCE AGREEMENT TAX CLAUSE, DOJ AND OFFSHORE NON-OCMPLIANCE, FBARS, IRS STREAMLINED FILING COMPLIANCE PROCEDURES, OFFSHORE ACCOUNTS, OFFSHORE TAX FRAUD, OVDP, SWISS BANK SETTLEMENT PROGRAM, SWISS BANKS, VOLUNTARY DISCLOSURE
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MORE ON INHERENT RISK IN STREAMLINED NON-WILLFUL CERTIFICATIONS
I have posted often about the risk of using the Streamlined Filing Compliance Procedures, specifically about the risk of making a statement under penalties of perjury of the reasons the taxpayer believes his or her conduct in failing to comply … Continue reading →
WAITING IS A DANGEROUS GAME FOR THOSE STILL NOT IN COMPLIANCE WITH FOREIGN REPORTING RULES
Over 55,000 taxpayers have come into compliance by entering the Offshore Voluntary Disclosure Program. An untold number of less culpable non-willful taxpayers have come into compliance under the Streamlined Filing Compliance Procedures. Some with reasonable cause have used the delinquent … Continue reading →
WILL-O -THE WISP NON-WILLFULNESS IN THE STREAMLINED FILING COMPLIANCE PROCEDURE
“A will-o’-the-wisp is an atmospheric ghost-light seen… at night, especially over bogs, swamps or marshes. It resembles a flickering lamp and is said to recede if approached, drawing (sojourners) from the safe paths.”(Wilkipedia). Most clients with unreported offshore accounts who … Continue reading →
Posted in TAX
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Tagged BANK SECRECY ACT, CERTIFICATION OF NON-WILLFULNESS, FBAR PENALTIES, FBAR QUESTION ON SCHEDULE B, FBARS, FOREIGN BANK ACCOUNTS, IRS STREAMLINED FILING COMPLIANCE PROCEDURES, MCBRIDE CASE, NONWILLFULNESS, OFFSHORE ACCOUNTS, OFFSHORE BANK ACCOUNTS, OFFSHORE TAX FRAUD, ROBERT S STIENBERG, VOLUNTARY DISCLOSURE, WILLFULNESS, WILLIAMS CASE
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RESIDENCE OF PARTICIPANTS IN 2009 OVDP AND FOREIGN COUNTRIES IN WHICH DISCLOSED FINACIAL ACCOUNTS WERE LOCATED
On January 6, 2014 the U.S. Government Account Office (GAO) reported to Senator Carl Levin, Chairman, Permanent Subcommittee on Investigations, Committee on Homeland Security and Governmental Affairs, certain information about the participants in the 2009 IRS Offshore Voluntary Disclosure Program … Continue reading →
WHY NOW IS A PROPITIOUS TIME FOR THOSE WITH UNREPORTED OFFSHORE ACCOUNTS TO MAKE A VOLUNTARY DISCLOSURE?
One oddity about the Offshore Voluntary Disclosure Program (OVDP) is that the FBAR years included in the criminal and reduced penalty partial-amnesty period are geared to one’s income tax filings. (IRS OVDP FAQ 9) Thus, once a correct income tax … Continue reading →
Posted in 2012 OVDP, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, TAX INFORMATION EXCHANGE AGREEMENTS, VOLUNTARY DISCLOSURE
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Tagged 2012 OVDP, BANK SECRECY ACT, FATCA, FBAR, FBAR PENALTIES, FBARS, FOREIGN BANK ACCOUNTS, OFFSHORE ACCOUNTS, OFFSHORE BANK ACCOUNTS, OFFSHORE TAX FRAUD, OVDP, OVDP BENEFITS, RAOUL WEIL, Robert S. Steinberg, SWISS BANK SETTLEMENT PROGRAM, SWISS BANKS, TAX HAVENS, VOLUNTARY DISCLOSURE
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LATEST DOJ ATTACK ON OFFSHORE ACCOUNTS: JOHN DOE SUMMONSES ISSUED TO U.S. CORRESPONDENT BANKS OF OFFSHORE BANKS
By now, I’m sure anyone owning an undisclosed offshore bank account has become familiar with the term, “John Doe Summons.” After all, following the IRS issuing a John Doe Summons to UBS, it announced the 2009 OVDP, and about 15,000 … Continue reading →
Posted in 2012 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, VOLUNTARY DISCLOSURE
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Tagged # INDIVISIBLE, 2012 OVDP, BANK SECRECY ACT, FATCA, FBAR, FBAR PENALTIES, FBARS, FOREIGN BANK ACCOUNTS, OFFSHORE ACCOUNTS, OFFSHORE BANK ACCOUNTS, OFFSHORE TAX FRAUD, OVDP, OVDP BENEFITS, Robert S. Steinberg, SWISS BANKS, TAX CRIMES, UBS, VOLUNTARY DISCLOSURE
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CAUTION: IRS MAY ALREADY HAVE YOUR NAME OR WILL SOON. OFFSHORE DRAGNET LEADS UNNAMED FOREIGN BANKS TO COOPERATE
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 →
Posted in 2012 OVDP, OFFSHORE BANK ACCOUNTS, TAX, TAX CRIMES, VOLUNTARY DISCLOSURE
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Tagged # INDIVISIBLE, 2012 OVDP, AMNESTY FOR OFFSHORE ACCOUNTS, BANK SECRECY ACT, FBAR PENALTIES, FBARS, FOREIGN BANK ACCOUNTS, H TY WARNER, OFFSHORE INDICTMENTS, OFFSHORE TAX FRAUD, OVDP, OVDP BENEFITS, Robert S. Steinberg, SWISS BANKS, VOLUNTARY DISCLOSURE
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THE WRONG QUESTION TO ASK ABOUT OFFSHORE ACCOUNTS: WHAT ARE THE ODDS OF BEING CAUGHT?
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 →
Posted in 2012 OVDP, TAX
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Tagged 2012 OVDP, BANK SECRECY ACT, FBAR PENALTIES, FBARS, OFFSHORE ACCOUNTS, OFFSHORE VOLUNTARY DISCLOSURE PROGRAM, TAX CRIMES, VOLUNTARY DISCLOSURE
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