Tag Archives: OVDP

DEPARTMENT OF JUSTICE ANNOUNCES FBAR GUILTY PLEA OF GREEN CARD HOLDER

On October 26, 2017, Hyung Kwon Kim (Kim), a Greenwich, Connecticut man pleaded guilty to failing to report funds he maintained in foreign bank accounts to the Department of Treasury. The DOJ Press Release was announced Acting Deputy Assistant Attorney … Continue reading

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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

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HOW NOT TO VOLUNTARILY DISCLOSE AN UNREPORTED OFFSHORE FINANCIAL ACCOUNT

A Wall Street Journal of March 14, 2015 by Laura Saunders reveals how Gregg Kaminsky and his tax advisors violated the cardinal rule of voluntary disclosure practice, “Don’t make things worse than they already are.” Kaminsky, now a 46 year-old … Continue reading

Posted in 2014 OVDP, AMENDED RETURNS, LESSONS FOR OFFSHORE TAX COMPLIANCE, ROBERT S STEINBERG, STREAMONED FILING COMPLIANCE PROCEDURES, WRONG WAY TO VOLUNTARILY DISCLOSE OFFHORE ACCOUNTS | Tagged , , , , | Leave a comment

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 | Tagged , , , , , , , , , , , , , , | 8 Comments

OFFSHORE VOLUNTARY DISCLOSURE PROGRAM (OVDP): STRICT APPLICATION OF 50% PENALTY CAN BE HARSH

Consider the following fact pattern: Father and daughter are participants in the OVDP who submitted their OVDP Letters after August 4, 2014.   Each owned separate unreported offshore bank accounts during the OVDP period 2006 through 2013. The father’s account was … Continue reading

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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

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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

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