Tag Archives: UBS

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

Posted on November 20, 2013 by steinbergtaxlaw

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

MORE STORM CLOUDS FOR HIDDEN OFFSHORE ACCOUNTS

Posted on November 1, 2013 by steinbergtaxlaw

The holes in which to hide for offshore tax cheats are steadily being filled up.  Those who have not entered the IRS Offshore Voluntary Disclosure Program, will find no comfort in some recent news, namely: Bank Frey, the “Truly Swiss, … Continue reading →

Posted in 2012 OVDP, OFFSHORE BANK ACCOUNTS, TAX, TAX CRIMES | Tagged , , , , , , , , , , , | Leave a comment

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

Posted on May 5, 2013 by steinbergtaxlaw

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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IRS TO GET MORE EASY PICKINGS OF OFFSHORE FRUIT

Posted on March 23, 2013 by steinbergtaxlaw

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

OFFSHORE VOLUNTARY DISCLOSURE UPDATE – JANUARY 2013

Posted on February 1, 2013 by steinbergtaxlaw

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

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 steinbergtaxlaw

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