Tag Archives: SWISS BANKS

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

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

Posted in STREAMLINED FILING COMPLIANCE PROCEDURES, Uncategorized | Tagged , , , , , , , , , | 3 Comments

STILL HAVE AN UNREPORTED FORIEGN FINANCIAL ACCOUNT? BEWARE THE TRUSTED ADVISORS: THEY WILL GIVE YOU UP TO SAVE THEIR OWN SKINS

The DOJ Press Release reproduced below in its entirety should be very scary to those still out in the cold with unreported foreign financial accounts.  We know that foreign banks are taking steps to minimize their risk of criminal prosecution … Continue reading

Posted in 2012 OVDP, 214 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX CRIMES, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , , | 2 Comments

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

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106 SWISS BANKS AGREE TO NAME NAMES OF US DEPOSITORS

My post of September 6, 2013, “Heat on Offshore Tax Evaders Turned up: DOJ Offers Swiss Government Sanctioned Deal to Smaller Swiss Banks,” described in some detail the Swiss Bank Settlement Program (SBSP) under which Swiss banks not already under … Continue reading

Posted in 2012 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, VOLUNTARY DISCLOSURE | Tagged , , , , , | Leave a comment

THE OFFSHORE DOMINOES ARE TUMBLING DOWN AND CREDIT SWISS WILL SOON FOLD

The Wall Street Journal reported today (“Credit Swiss Nears Tax-Cheat Deal,” by John Letzing, Francesco Guerrera and David Enrich) ) that Credit Swiss, Switzerland’s second largest bank, is said to be in serious negotiations with the Department of Justice to … Continue reading

Posted in 2012 OVDP, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, VOLUNTARY DISCLOSURE | Tagged , , , , , , | Leave a comment

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