This week John Koskinen, IRS Commissioner, claimed success based upon FATCA driven voluntary disclosures by US taxapayers. The IRS disclosed more than $10 Billion collected from FBAR compliance through the Offshore Voluntary Disclosure Program or OVDP and the Streamlined Domestic Offshore Procedures. “The IRS has passed several major milestones in...
IRS FBAR Audits and Prosecutions Have Begun
The IRS FBAR audits and prosecutions have begun and the clock is ticking for those who have yet to come into full FBAR compliance with the IRS. A Connecticut man recently plead guilty to the offshore scheme he used to conceal income from the IRS. The man, a duty-free importer...
Texas Case Shows a Piece of IRS Offshore Willful Analysis Strategy
Earlier this year the IRS, with the help of a US Bankruptcy Judge, successfully pierced a complex strategy by two Texas brothers Sam and Charles Wyly. The Wyly brothers were accused by the IRS of tax fraud related to the funneling of money and assets to offshore banks through a comprehensive series...
What does a Professional Foreign National Working in San Diego Need to Know about the IRS?
Have you come into the San Diego area on an H1-B visa in order to work in one of our high tech or research companies? What does a professional foreign national working in San Diego need to know about the IRS, offshore account and asset reporting and FBAR compliance? Many...
San Jose Indian Foreign National Given Six Month Prison Term for Hiding Offshore Accounts from the IRS
We have advised foreign nationals living and working in the United States to come into compliance with IRS FBAR requirements for quite some time. One recent example of the risks faced by failing to come into FBAR compliance is a six month prison sentence to an Indian foreign national who...
What Happens if the IRS Rejects your FBAR Streamlined Application
Did you file an application under the IRS Streamlined Domestic (Foreign) Offshore Procedures? What happens if the IRS rejects your FBAR streamlined application and claims of non-willful conduct? What actions have been taken by the IRS that concern the attorneys at Allen Barron? Let's begin with the last question first....
Should You Report Previous Offshore Income Through an FBAR Voluntary Disclosure
A storm is on the horizon for those who fail to report offshore financial activity to the IRS. We are often asked by clients, especially foreign nationals who live and work here in the San Diego area, if they should report previous offshore income to the IRS through an FBAR...
Why Should a Foreign National Working or Residing in the US Care about FBAR Compliance
Why should a foreign national working or residing in the US care about IRS FBAR compliance? "None of my friends or associates are aware of this or worried about it..." is a sentiment we often hear. Unfortunately, the IRS isn't interested in what a foreign national working or residing in...
Appeal of FBAR Willful Violation Civil Penalty to 5th Circuit
In a technical legal move Bernhard Gubser, a dual US / Swiss citizen, asked the 5th Circuit Court to hear an appeal of his case against the IRS regarding a $1.4 Million FBAR willful violation civil penalty case which was tossed out by a lower court earlier this year. Mr....