by Igor Drabkin | Jul 10, 2015 | FBAR, Internal Revenue Service, Offshore Income
We have previously posted news about more foreign banks reaching non-prosecution agreements with the Department of Justice, resulting in the turn over of U.S. account holders’ information to the U.S. authorities. In fact, the list of the banks on the IRS list... 
by Gary Slavett | Jun 5, 2015 | FBAR, Internal Revenue Service, Offshore Income
By now, many taxpayers with foreign accounts have heard of the FBAR (Report of Foreign Bank and Financial Accounts) and the different penalties for failing to file the FBAR. However, many of our new clients are still not familiar with Form 8939 (Statement of Foreign... 
by Gary Slavett | Jun 5, 2015 | Criminal Tax, Internal Revenue Service, Offshore Income
Rothchild Bank, AG, and Bank Credivest SA, have reached a resolution with the U.S. Department of Justice (“DOJ”) under the DOJ’s Swiss Bank Program. Under the non-prosecution agreement, each bank agrees to cooperate in any related criminal or civil... 
by Igor Drabkin | Jun 5, 2015 | FBAR, Internal Revenue Service, Offshore Income
On May 28, 2015, the Department of Justice announced that four additional Swiss banks reached Non-Prosecution Agreements (NPA) with the United States, pursuant to the Swiss Bank Disclosure Program. These banks include Société Générale Private Banking... 
by Igor Drabkin | Apr 8, 2015 | Criminal Tax, Internal Revenue Service, Offshore Income
Peter Amrein, a former banker at a Swiss asset management firm, pleaded guilty last month to a tax conspiracy charge in the Southern District of New York, acknowledging his responsibility for helping U.S. taxpayers hide millions of dollars in offshore accounts from... 
by Igor Drabkin | Mar 3, 2015 | FBAR, Firm News, Internal Revenue Service, Offshore Income
Igor Drabkin’s article “International Reporting Penalties — What to Expect and How to Fight Them” was published in the January 2015 edition of the CCH Journal of Tax Practice and Procedure. The Journal of Tax Practice and Procedure is...