Tag Archives: FBARS

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

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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

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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

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ARE OFFSHORE CHEATS GETTING OFF TOO EASY?

A recent Wall Street Journal Article, “Leniency for Offshore Cheats,” by Laura Saunders cited statistics that reveal a discrepancy between sentences handed down in offshore cases versus those dolled out in tax shelter criminal cases.  The article reports: The average … Continue reading

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IRS TO GET MORE EASY PICKINGS OF OFFSHORE FRUIT

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

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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OVDP 2012 UPDATE

The third formal Offshore Voluntary Disclosure Program (OVDP 2012) was announced on January 9, 2012. The IRS finally got around to posting Frequently Asked Questions (FAQS) on its website on June 26, 2012.  The Tax Wars Blog post on August 6, … Continue reading

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