Archive | Voluntary Disclosure

Credit Suisse and the IRS

May 21, 2014  |   Posted by :   |   Tax Evasion,Unreported Income,Voluntary Disclosure   |   1 Comment

After more than 100 years of creating “secret offshore accounts” held covertly in the names of “sham entities and foundations”, on 5/19/14, Switzerland’s 2d biggest bank, Credit Suisse (“CS”) plead guilty to tax evasion (one count of conspiracy to commit tax evasion). CS agreed to pay $2.6B in federal and New York state penalties, and hire […]

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IRS Offshore Voluntary Disclosure Program 2014

February 05, 2014  |   Posted by :   |   Tax Evasion,Voluntary Disclosure   |   0 Comments

Kathy Keneally, U.S. Assistant Attorney General, advised that 106 Swiss banks have agreed to non-prosecution agreements with the U.S. government and will provide data on those U.S. taxpayers who hid assets in these Swiss banks. These Swiss banks are sending letters to these U.S. customers advising them to enter the IRS Voluntary Disclosure program. In […]

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IRS Voluntary Disclosure 2013: An Update

October 05, 2013  |   Posted by :   |   Tax Evasion,Unreported Income,Voluntary Disclosure   |   0 Comments

Two recent cases demonstrate the great risk attendant to the IRS offshore Voluntary Disclosure Program (2012-forward) (“OVDP”). In the Bank Leumi case, dozens of U.S. taxpayers with accounts at Bank Leumi were in 2013 peremptorily disqualified from the IRS OVDP without explanation. The IRS has recently reversed this position and according to tax counsels have […]

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Beanie Baby Creator Ty Warner Charged with Tax Evasion

September 21, 2013  |   Posted by :   |   Tax Evasion,Unreported Income,Voluntary Disclosure   |   0 Comments

Ty Warner, billionaire founder of Beanie Babies toys, after a failed attempt to enroll in the IRS Offshore Voluntary disclosure Program, has been charged with federal tax evasion and has agreed to pay a $53.5million penalty for failing to report income earned in a secret offshore account held at UBS in Switzerland. Warner, ranked 209th […]

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IRS Offer in Compromise

June 02, 2013  |   Posted by :   |   Voluntary Disclosure   |   0 Comments

The IRS may compromise the tax liability in most civil or criminal cases before referral to the Department of Justice for prosecution or defense. The Attorney General or a delegate may compromise any case after the referral. However, the IRS may not compromise certain criminal liabilities arising under internal revenue laws relating to narcotics, opium, […]

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IRS Unreported Income – Jeopardy Assessment

June 02, 2013  |   Posted by :   |   Unreported Income,Voluntary Disclosure   |   0 Comments

Under a jeopardy assessment, Taxpayers who have unreported income may be subject to immediate IRS seizure of assets. If the IRS determines that tax collection is at risk, the IRS may immediately seize taxpayer assets without prior notice. The IRS must have made a determination that a deficiency existed and that tax collection would be […]

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Voluntary Disclosure – Early History

May 28, 2013  |   Posted by :   |   Voluntary Disclosure   |   0 Comments

A tax crime is complete on the day the false return was filed. Between 1945 and 1952, the IRS had a “voluntary disclosure” policy under which a taxpayer who failed to file a return or declare his full income and pay the tax due could escape criminal prosecution through voluntary disclosure of the deficiency, (so […]

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IRS Eyes U.S. Accounts at Caribbean Bank

May 28, 2013  |   Posted by :   |   Tax Evasion,Voluntary Disclosure   |   0 Comments

“IRS eyes U.S. accounts at Caribbean bank” by Nanette Byrnes, Reuters, 4/30/13 U.S. Department of Justice said April 30, 2013 that a federal court has authorized the IRS to seek information on U.S. taxpayers who may have accounts at Canadian Imperial Bank of Commerce, First Caribbean International Bank (FCIB). The U.S. Justice Department said a […]

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Voluntary Disclosure – Yes or No?

May 15, 2013  |   Posted by :   |   Tax Evasion,Voluntary Disclosure   |   0 Comments

by Sanford Passman, Esq. and Gary S. Wolfe The Internal Revenue Service (“IRS”) Offshore Voluntary Disclosure Program (2012) is offered by the IRS to American taxpayers who may be in violation of U.S. tax laws for a myriad of reasons. Given the enormous sums of money which are spirited to offshore tax havens throughout the world, […]

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IRS Voluntary Disclosure Initiative – Post-UBS Agreement

May 08, 2013  |   Posted by :   |   Tax Evasion,Voluntary Disclosure   |   0 Comments

On 3/23/09, the IRS issued three memoranda regarding the voluntary disclosure of offshore accounts with the following key points: 1. The IRS was prioritizing audit examinations and investigations of abusive offshore transactions designed to evade the payment of U.S. taxes; 2. The Criminal Investigation Division (“CID”) of the IRS was made responsible for initially screening […]

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