Tag Archives: VOLUNTARY DISCLOSURE

SOME ADVANTAGES AND DISADVANTAGES OF STREAMLINED PROCEDURES FOR U.S. CITIZENS AND RESIDENTS RESIDING IN THE U.S.

“Beware of false knowledge; it is more dangerous than ignorance.” – George Bernard Shaw Shaw’s admonition is applicable to the recently announced Streamlined Process and Transitional as alternatives for resolving offshore noncompliance exposure of U.S. citizens and residents.  Calls I’ve … Continue reading

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ON FBAR WILLUL NON-FILING AND WILLFUL BLINDNESS – THE RUMSFELD DISCLAIMER

In United States v. Williams, (2012), the Fourth Circuit Court of Appeals reversed the District Court’s holding that Williams’ failure to file an FBAR that was due June 30, 2001 was a non-willful failure to file because the government already … Continue reading

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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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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

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IRS AND DOJ BANK DISCLOSURE SNOWBALL KEEPS ROLLING DOWNHILL BECOMING LARGER WITH EACH TURN

The Department of Justice (DOJ) website correctly states that the division’s investigations encompass “an ever-widening circle of banks.”  Recent events prove this statement true. Investigations are under-way on 14 of the largest banks in Switzerland, and banks in India, Israel … Continue reading

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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

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CAUTION: IRS MAY ALREADY HAVE YOUR NAME OR WILL SOON. OFFSHORE DRAGNET LEADS UNNAMED FOREIGN BANKS TO COOPERATE

Some still out in the cold with offshore financial accounts take comfort in the fact that their bank has not yet been indicted or named in any publicly announced IRS investigation.  Well, here is some sobering news to shake confidence … Continue reading

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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

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OVDP OR NOTHING AT ALL

The 1939 song, “All or Nothing at All,” (by Arthur Altman and Jack Lawrence) made popular by Frank Sinatra might be sung in a new version by IRS, “OVDP or Nothing at All.” The Bank Secrecy Act contains draconian penalties … Continue reading

Posted in 2012 OVDP, AMENDED RETURNS, DELINQUENT RETURN, FBARS, NEW OVDP, TAX, TAX CRIMES, VOLUNTARY DISCLOSURE | Tagged , , , , , , , , , , , , | Leave a comment

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

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