Tag Archives: OFFSHORE BANK ACCOUNTS

LATEST DOJ ATTACK ON OFFSHORE ACCOUNTS: JOHN DOE SUMMONSES ISSUED TO U.S. CORRESPONDENT BANKS OF OFFSHORE BANKS

Posted on November 20, 2013 by taxpenaltylawyer

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 | Tagged , , , , , , , , , , , , , , , , , | Leave a comment

HEAT ON OFFSHORE TAX EVADERS TURNED UP: DOJ OFFERS SWISS GOVERNMENT SANCTIONED DEAL TO SMALLER SWISS BANKS

Posted on September 6, 2013 by taxpenaltylawyer

Recent developments have turned up the heat on offshore tax holders who have or have had unreported bank accounts in Switzerland: On August 29, 2013, the U.S. Department of Justice (DOJ) and Swiss Federal Department of Finance issued a joint … Continue reading →

Posted in 2012 OVDP, FBARS, TAX, TAX CRIMES, TAX INFORMATION EXCHANGE AGREEMENTS, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , | Leave a comment

ARE OFFSHORE CHEATS GETTING OFF TOO EASY?

Posted on May 11, 2013 by taxpenaltylawyer

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

Posted on May 5, 2013 by taxpenaltylawyer

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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OFFSHORE VOLUNTARY DISCLOSURE UPDATE – JANUARY 2013

Posted on February 1, 2013 by taxpenaltylawyer

LEVEL OF PARTICIPATION IN PROGRAMS On June 26, 2012 the IRS had released IR-2012-64, which stated:  Shulman (IRS Commissioner Doug Shulman) said the IRS offshore voluntary disclosure programs have so far resulted in the collection of more than $5 billion … Continue reading →

Posted in 2012 OVDP, AUDITS, FBARS, NEW OVDP, TAX, TAX CRIMES, 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 taxpenaltylawyer

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 taxpenaltylawyer

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