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Tax Crime Does Not Pay — Says Department of Justice

Tax Crime Does Not Pay — Says Department of Justice

by Igor Drabkin | Apr 11, 2018 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income

On April 10, 2018, just before the tax filing deadline, the U.S. Department of Justice issued an announcement, reminding the public of tax obligations and highlighting a number of criminal tax cases.  The DOJ reminds that evading one’s tax obligations could end...
IRS Offshore Voluntary Disclosure Program to End Soon

IRS Offshore Voluntary Disclosure Program to End Soon

by Igor Drabkin | Mar 13, 2018 | FBAR, Internal Revenue Service, Offshore Income

In the news release issued today, March 13, 2018, the Internal Revenue Service announced that the Offshore Voluntary Disclosure Program (OVDP) will close on September 28, 2018.  The deadline gives U.S. taxpayers with non-compliant undisclosed foreign accounts and...
Tax Court Rules for Taxpayer on Statute of Limitations Issue Related to Foreign Assets Reporting

Tax Court Rules for Taxpayer on Statute of Limitations Issue Related to Foreign Assets Reporting

by Igor Drabkin | Jan 8, 2018 | FBAR, Internal Revenue Service, Offshore Income, Tax Litigation

In Rafizadeh v. Commissioner, 150 T.C. No. 1, the Tax Court issued an important decision for the taxpayers, holding that the six-year statute of limitations with respect to income attributable to certain “specified foreign financial assets”, is effective only for...
Southern California Residents Sentenced to Prison for Hiding Millions of Dollars in Secret Foreign Bank Accounts

Southern California Residents Sentenced to Prison for Hiding Millions of Dollars in Secret Foreign Bank Accounts

by Igor Drabkin | Apr 25, 2017 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income

Three Orange County, California residents, Dan Kalili, his brother David Kalili, and David Azarian, were sentenced to prison today for willfully failing to file Foreign Bank Account Reports (FBAR), disclosing their secret accounts in Switzerland and Israel. The three...
New Due Date for Filing Foreign Bank Account Reports (FBAR) in 2017

New Due Date for Filing Foreign Bank Account Reports (FBAR) in 2017

by Igor Drabkin | Jan 25, 2017 | FBAR, Internal Revenue Service

Beginning this year, reporting for the 2016 calendar year, the due date for filing Foreign Bank Account Reports (FBAR) changes from June 30th (which applied to all the previous tax years) to the same filing deadline as individual income tax returns, April 15.  Like...
IRS Offshore Voluntary Disclosure Program Status and Recent Developments

IRS Offshore Voluntary Disclosure Program Status and Recent Developments

by Igor Drabkin | Nov 2, 2016 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income

On October 21, 2016, the IRS issued a news release, announcing new data on the Offshore Voluntary Disclosure Procedures, which were put in place by the IRS in order to bring taxpayers with undisclosed foreign accounts and offshore assets into compliance. According to...
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  • Richard Gano to Speak on IRS Estate & Gift Tax Audits at the 12th Annual Virtual Young Tax Lawyers Conference
  • Michele Weiss to Speak on an Ethics Panel at the ABA Tax Conference on May 8, 2026, in Washington, DC
  • David J. Warner to Analyze IRS Audits of S Corporations in National Webinar
  • Super Lawyers Names Six HSDW Attorneys to 2026 Southern California Super Lawyers and Rising Stars Lists
  • Michele Weiss to Moderate a Panel on FTB and CDTFA Settlement for the Beverly Hills Bars Association
  • Michele Weis to Discuss Valuation in Tax Cases: The Importance of Getting it Right at the USC Tax Institute on January 27, 2026
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