by Igor Drabkin | Jan 14, 2015 | FBAR, Internal Revenue Service, Offshore Income
On December 30, 2014, the Internal Revenue Service updated its list of Foreign Financial Institutions or Facilitators, whose clients meet criteria for a 50% Penalty in the Offshore Voluntary Disclosure Program (OVDP). The list now includes: 1) UBS AG 2) Credit Suisse... 
by Igor Drabkin | Nov 4, 2014 | Criminal Tax, Internal Revenue Service, Offshore Income
Raoul Weil, a former UBS AG banker, who headed their global wealth management group, was found not guilty yesterday by the federal jury in Fort Lauderdale, Florida. The jury reached its not guilty verdict after deliberating for a little over an hour. Weil was... 
by Igor Drabkin | Aug 6, 2014 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income
Another victory for the government in their fight against hidden offshore accounts was announced today in Los Angeles. Monajem Hakimijoo (aka Manny Hakim), a Beverly Hills, California resident, was sentenced today in the U.S. District Court for the Central District... 
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...