by Igor Drabkin | Dec 2, 2018 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income
On September 28, 2018, the Internal Revenue Service ended the Offshore Voluntary Disclosure Program (2014 OVDP), which was designed for taxpayers with exposure to potential criminal liability or substantial civil penalties due to a willful failure to report foreign... 
by David J. Warner | Nov 13, 2018 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income
Certain individuals and entities are required to file a FinCEN Form 114, Report of Foreign Bank Account Report (commonly called an “FBAR”), if they have a financial interest or signature authority in a foreign bank account. The FBAR form is filed electronically on the... 
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... 
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... 
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... 
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...