The University of Rochester has gained unexpected notoriety recently as one of it's professors faces sentencing in a criminal tax evasion scheme. The University professor pays a $100 Million FBAR penalty to the IRS for failure to disclose Swiss accounts while awaiting his sentence in February that may contain additional...
Argentina’s Aggressive Offshore Tax Strategy Results in Threat to Account Holders of Major US Bank
The implementation of global forms of the US FATCA tax initiative, often referred to as GATCA (Global FATCA) continue to gain steam in Central and South America. This week a major US bank threatened to close the accounts of Argentinians with "undeclared funds." JP Morgan announced this week that "all funds...
Mexico and South America to Implement Their Own FATCA Regulations
Just when many thought the wave of IRS focus on offshore accounts and investments had passed the next wave has reached our shores. The recent decisions by Mexico and South America to implement their own FATCA regulations means a continued tightening of inter-agency communication and international monetary tracking. The success...
IRS Disclosed More than $10 Billion Collected from FBAR Compliance
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...
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...
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...
Lawsuit against IRS Offshore Tax Programs Dismissed
Another lawsuit challenging the IRS offshore tax programs has been dismissed. In the consolidated lawsuit, 3 plaintiffs attempted to assert that they should be able to switch to the IRS' streamlined domestic offshore procedures, which were not available when the 3 filed applications under the OVDP or Offshore Voluntary Disclosure...
Willful or Non-Willful Attempt to Avoid US Taxes?
There continues to be confusion regarding what constitutes a willful or non-willful attempt to avoid US taxes as it relates to offshore bank accounts, investments, assets and income. The IRS has purposefully failed to clarify this issue over the past 7 years. This is the first piece of evidence a...
The World is Becoming Much Smaller for Tax Evasion
It is a bitter pill to swallow. There are fewer and fewer secrets. The world is becoming much smaller for tax evasion and the authorities have broken the backs of banks and financial institutions worldwide. They have used FATCA to drag huge Swiss Banks and Cayman Island institutions into court...