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Blog Profile / Tax Problem Attorney Blog


URL :http://www.taxproblemattorneyblog.com/
Filed Under:Business & Finance / Taxes
Posts on Regator:96
Posts / Week:0.5
Archived Since:March 8, 2011

Blog Post Archive

New FAQs For Offshore Voluntary Disclosure Program (OVDP) Released by IRS

Our tax lawyers have reviewed the IRS' newly issued FAQs for its Delinquent International Information Return Submission Procedures, the Streamlined Filing Compliance Procedures for U.S. Taxpayers Residing in the United States (SDOP), and the Streamlined Filing Compliance Procedures for U.S. Show More Summary

Florida Doctor Sentenced in Criminal Tax Case for Concealing Assets and Filing False Individual Income Tax Returns

Individuals using offshore bank accounts to conceal assets and facilitate tax fraud continue to be prosecuted by the Department of Justice. Under the Bank Secrecy Act, citizens and lawful permanent residents (i.e. "Green Card" holders)...Show More Summary

Business Owners Get Jail Time for Tax Evasion

Sometimes understating income is just carelessness. Sometimes its tax fraud or tax evasion. People don't always realize that tax fraud or tax evasion can lead to time in jail. Convincing judges to sentence defendants to prison for criminal...Show More Summary

Expect Increased Assessment and Collection of Trust Fund Recovery Penalties

Enforcement of The Trust Fund Recovery Penalty (TFRP) is a source of potential government revenue that, according to the Treasury Inspector General for Tax Administration (TIGTA), needs to be revamped to become more efficient. UnderShow More Summary

Big Changes to IRS Offshore Voluntary Disclosure Program (OVDP) for FBAR Non-Filers

Massive change is coming to the IRS Offshore Voluntary Disclosure Program (OVDP). These changes will affect different groups of taxpayers differently, and it will be at least a few days before tax attorneys have had an opportunity to make sense of it all. Show More Summary

Swisspartners Group Entered Into NPA to Avoid Criminal Tax Prosecution But Must Pay $4.4 Million in Forfeiture and Restitution for Assisting U.S. Tax Evasion

To avoid prosecution for tax evasion and other alleged crimes, the Swisspartners Investment Network AG, a Swiss-based asset management firm, and three of its wholly-owned subsidiaries (collectively, the Swisspartners Group) entered into a non-prosecution agreement (NPA) with the U.S. Show More Summary

Grim Outlook for Congressman Michael Grimm after 20-Count Indictment Alleging Tax Fraud

Congressman Michael Grimm faces a 20-count indictment in federal court for allegedly committing tax fraud, and evading taxes by concealing more than $1million in sales and understating wages. He is charged with five counts of mail fraud,...Show More Summary

Offshore Bahamian Vacation Comes To An End

An alleged tax fraud scheme by Victor Lipukhin, the former president of a large Russian steel company resulted in a recent grand jury indictment. According to court papers, he hid between $4 million and $7.5 million dollars in Swiss bank accounts at UBS from 2002 through 2007. Show More Summary

Bank of Israel Orders FACTA Implementation

To help prevent tax evasion through the use of offshore accounts, the U.S. Treasury Department, enacted regulations under the Foreign Account Tax Compliance Act (FATCA), that go into effect July 1, 2014. At the end of March, the Bank...Show More Summary

IRS Criminal Tax Investigation Interesting Facts

Criminal tax cases generally start out in the IRS' Criminal Investigation (CI) division. It is therefore instructive to look at CI's annual report that was issued earlier this year for the 2013 fiscal year. To some extent, there were no surprises. Show More Summary

Will the Justice Department Seek Extradition of Swiss Bankers Charged With Aiding and Abetting Tax Evasion by U.S. Citizens?

According to two U.S. Senators, Switzerland has not sought extradition of a single Swiss national charged with criminal conduct that was related to aiding and abetting U.S. tax evasion for more than five years. In a recent letter authored...Show More Summary

A Tale of Two FBAR Doctors and Why Even a Quiet Voluntary Disclosure May be Valuable

The tax evasion conviction of Dr. Edward Picardi was upheld by the Eighth Circuit last month. Also upheld was his conviction for failure to file Foreign Bank Account Reports (FBARs), Form TDF 90-22.1. Picardi was sentenced to five years in jail. Show More Summary

Mizrahi Bank of Israel Offshore Account Holder Pleads Guilty to Criminal Tax Violations

A Mizrahi Bank customer pled guilty to filing a false tax return in connection with an undisclosed offshore Israeli bank account, in violation of IRC Section 7206(1). Mizrahi Bank, located in Israel but with a U.S. affiliate, has been linked to the Department of Justice criminal tax investigation of undisclosed foreign accounts. Show More Summary

Taxpayer Advocate's 2013 Report to Congress Again Critical of Offshore Voluntary Disclosure Program (OVDP) for Unreported Foreign Bank Accounts (Part I)

The Offshore Voluntary Disclosure Program (OVDP) for taxpayers who have failed to file Foreign Bank Account Reports (FBARS), FINCEN Form 114, (this form was previously designated as TDF 90-22.1), has again been roundly criticized by the Taxpayer Advocate for its draconian penalties, and its one size fits all solution. Show More Summary

Collection Due Process (CDP) Hearing Requests Sent to the Wrong IRS Office Creates Tax Problems

For the IRS to issue a tax levy to garnish bank accounts, wages or other assets it, generally, must first issue a Collection Due Process or CDP Notice. The CDP Notice is required by Internal Revenue Code Section 6330. The CDP noticeShow More Summary

Foreign Bank Account Owner at Julius Baer Wins Round One

The Swiss Federal Administrative Court has blocked Swiss Bank Julius Baer from turning over one of its client's offshore bank account information to the Internal Revenue Service according to a report in Bloomberg News. On April 17, 2013...Show More Summary

More Reasons Why Quiet Voluntary Disclosures as an Alternative to the Offshore Voluntary Disclosure Program (OVDP) Have Become Riskier

Based upon anecdotal evidence, foreign bank account owners are opting to enter the Offshore Voluntary Disclosure Program (OVDP) more frequently in the last few months. In November, I blogged about why quiet voluntary disclosures are becoming more risky. Show More Summary

Tax Fraud Investigation Leads to California Construction Company Owner's Guilty Plea to Criminal Tax Charges

Civil tax problems were the least of Brian Kenny's worries on Thanksgiving. The California construction company owner, age 40, of San Francisco, pled guilty in November to filing false tax returns for his company, SF Bay Construction,...Show More Summary

Quiet Voluntary Disclosures as an Alternative to the Offshore Voluntary Disclosure Program (OVDP) Are Becoming More Risky

Owners of foreign bank accounts who have failed to file foreign bank account reports (FBAR) have several options to clean up this ugly tax problem. I briefly discussed them in a recent webinar, and in the related PowerPoint presentation. Show More Summary

Important Offer in Compromise (OIC) Tip from a Senior IRS Collection Official

An Offer in Compromise (OIC) can be one of the best ways to avoid an IRS tax levy, and to reduce your tax debt if you have fallen far behind. Earlier this month I was speaking with a senior IRS collection official about Offers in Compromise, and he brought up an interesting point. Show More Summary

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