by Igor Drabkin | Jun 26, 2014 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income
Last week the IRS announced major changes to the Offshore Voluntary Disclosure Program (OVDP). These changes include some good news for taxpayers who non-willfully failed to comply with Foreign Bank Account Reporting (FBAR), but also include a higher penalty (50% of... 
by Igor Drabkin | Jun 2, 2014 | FBAR, Internal Revenue Service, Offshore Income, Tax Collection
The issue of FBAR penalties often is raised in our practice by prospective clients who consider entering into the Offshore Voluntary Disclosure Program (OVDP). One of the questions is whether the IRS can realistically go after the penalty, which is more than 27.5% of... 
by Igor Drabkin | May 5, 2014 | FBAR, Internal Revenue Service, Offshore Income
On Friday, May 2, 2014, the . IRS Notice 2014-33 announces that during this transition period, the IRS will take into account the extent of good faith efforts to comply with the requirements of the chapter 4 regulations and the temporary coordination regulations by... 
by Igor Drabkin | Apr 30, 2014 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income
According to numerous sources, the Swiss units of Goldman Sachs and Morgan Stanley are among more than 100 Swiss banks and financial institutions, participating in the Department of Justice amnesty program, which provides non-prosecution agreements to the banks in... 
by Igor Drabkin | Dec 17, 2013 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income
On August 29, 2013, the U.S. Department of Justice and the Swiss Federal Department of Finance issued a joint statement, announcing a Program for Swiss Banks, which encouraged the banks to come clean in exchange for a Non-Prosecution Agreement by the U.S. government. ... 
by Igor Drabkin | Oct 29, 2013 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income
In the most recent case of government’s crackdown on offshore tax evasion, a Florida psychiatrist, who together with her husband founded two Caribbean medical schools, was found guilty of conspiring to defraud the Internal Revenue Service and filing false tax...