The U.S. Supreme Court has ruled that the $10,000 penalty for a nonwillful violation of the foreign bank account reporting rules in the Bank Secrecy act applies on a “per-form” basis, not a “per-account” basis, handing individuals an important victory.
Continue Reading U.S. Supreme Court Rules Against Government in FBAR Penalty Case
January 28, 2019 – Alerts
Following the termination last fall of its immensely successful Offshore Voluntary Disclosure Program (OVDP), the Internal Revenue
Continue Reading The New IRS Voluntary Disclosure Regime: Worth the Price of Admission?
Today the Internal Revenue Service released its long-awaited updated procedures for voluntary disclosures now that the much-heralded Offshore Voluntary Disclosure Program (OVDP) closed on September 28, 2018. The updated procedures
Continue Reading IRS Unveils Post-OVDP Voluntary Disclosure Procedures
On September 29, 2018, the Internal Revenue Service closed for good the long-running Offshore Voluntary Disclosure Program (OVDP), its hugely successful tax amnesty program for undisclosed offshore financial assets. Since
Continue Reading Despite Closure of OVDP, Offshore Tax Evasion Crackdown Marches On
The Internal Revenue Service has issued its annual reminder to taxpayers that they report their foreign assets on their individual tax returns due on April 17, 2018. Individuals with offshore
Continue Reading Internal Revenue Service Reminds Taxpayers to Report Offshore Bank Accounts on FBAR Form
August 29, 2017 – Law360
Continue Reading DOJ Offshore Bank Resolution Offers Cooperation Road Map
The Justice Department revealed its latest offshore bank resolution by announcing that it had entered into a non-prosecution agreement with a Swiss asset management firm called Prime Partners. This means
Today the Justice Department’s Tax Division announced that it has reached final resolutions with the remaining “Category 3 and 4” Swiss banks who had enrolled in the Swiss Bank Program
Continue Reading DOJ Announces Final Resolutions Under Its Groundbreaking Swiss Bank Program As Program Enters “Legacy” Phase
Effective today, 47 new names have been added to the Internal Revenue Service’s ever-expanding list of “Foreign Financial Institutions or Facilitators” which trigger a significantly higher penalty for
Continue Reading IRS Adds Nearly 50 New Names to OVDP Facilitator List, Effective November 15
The Internal Revenue Service has achieved another milestone in its long-running campaign to crack down on offshore tax evasion, announcing that more than 100,000 taxpayers have voluntarily returned to compliance
Continue Reading Internal Revenue Service Announces Major Milestone in Offshore Tax Crackdown