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Tag Archives: TAX CRIMES
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 →
Posted in 214 OVDP, FBARS, OFFSHORE BANK ACCOUNTS, TAX, VOLUNTARY DISCLOSURE
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Tagged BANK SECRECY ACT, FBAR PENALTIES, FOREIGN BANK ACCOUNTS, IRS STREAMLINED FILING COMPLIANCE PROCEDURES, OVDP, OVDP BENEFITS, QUIET DISCLOSURES, RISK OF PROSECUTION IN OFFSHORE CASE, ROBERT S STIENBERG, TAX CRIMES, VOLUNTARY DISCLOSURE, WILLFULNESS
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SOME SWISS BANKS ARE MORE THAN ENCOURAGING U.S. CLIENTS TO ENTER THE OVDP – THEY ARE OFFERING FINANCIAL INCENTIVES
An article in the Wall Street Journal on July 19, 2014 by John Letzing (“Taxpayers Get Incentives to Report: Swiss Banks Aim to Entice Americans to Disclose Accounts to IRS by Helping Cover Costs, Penalties”), reveals what many professionals have … Continue reading →
Posted in 2012 OVDP, 214 OVDP, FBARS, NEW OVDP, OFFSHORE BANK ACCOUNTS, TAX, TAX CRIMES, VOLUNTARY DISCLOSURE
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Tagged 2012 OVDP, BANK SECRECY ACT, FBAR, FBAR PENALTIES, FOREIGN BANK ACCOUNTS, OFFSHORE ACCOUNTS, OFFSHORE TAX FRAUD, OVDP, ROBERT S STIENBERG, SWISS BANK FINANCIAL INCENTIVES, SWISS BANK SETTLEMENT PROGRAM, TAX CRIMES, VOLUNTARY DISCLOSURE
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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
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Tagged 2012 OVDP, BANK SECRECY ACT, FBAR, FBAR PENALTIES, FOREIGN BANK ACCOUNTS, OFFSHORE ACCOUNTS, OFFSHORE BANK ACCOUNTS, OFFSHORE TAX FRAUD, OVDP, OVDP BENEFITS, ROBERT S STIENBERG, SWISS BANKS, TAX CRIMES, 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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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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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 →
OFFSHORE PROBES EXPAND BEYOND SWITZERLAND: NOMINEE ENTITY FAILS TO SHIELD TRUE ACCOUNT OWNER
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 →
FILING CORRECTIVE AMENDED RETURNS HELD NOT EXCULPATORY WITH REGARD TO CRIME OF FILING FALSE RETURNS
The Department of Treasury publishes a Criminal Tax Bulletin that summarizes significant criminal tax cases. The April-September Bulletin, among other cases, discusses United States v. Ellefsen, 655 F.3d 769 (8th Cir.2011), The case deals with the so-called “Brady Rule’ named … Continue reading →
Posted in AMENDED RETURNS, TAX, Uncategorized
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Tagged BRADY RULE, CRIMINAL TAX, FALSE RETURNS, TAX CRIMES
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