Tag Archives: fbar

IRS Criminal Tax Cases 2016 – S. Hyatt

December 30, 2016  |   Posted by :   |   Tax Evasion   |   0 Comments

Saul Hyatt of Weston, CT, used a Panamanian bank account to conceal over $1.5m in income from the sale of duty-free alcohol and tobacco products He plead guilty (9/16) to one count of conspiring to conceal assets and income from the IRS in an undeclared bank account in Panama held for his benefit. Hyatt allegedly […]

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FATCA-FBAR Update

October 21, 2015  |   Posted by :   |   FATCA/FBAR   |   0 Comments

On 10/2/09, the IRS confirmed it has begun exchanging tax information from certain foreign governments under the Foreign Account Tax Compliance Act (“FATCA”), to meet a September 30, 2015 deadline ( over 5 years after FATCA was passed as law in March 2010). To date Australia has given the US tax information on 30,000 US […]

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IRS Issues New Examiner FBAR Penalty Guidance

July 30, 2015  |   Posted by :   |   FATCA/FBAR   |   0 Comments

The IRS issued new examiner FBAR penalty guidance (SBSE-04-0515-0025) effective 5/13/15 for all FBAR cases (Fincen Form 114) open as of that date. Most importantly, the examiner is allowed to increase the maximum penalty from 50% to 100% of the offshore account balance (plus interest). Effectively, with the penalty (and interest) on the unreported account […]

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FBAR Penalties (2015): Taxpayer Willfulness & Required Records Exception

April 28, 2015  |   Posted by :   |   FATCA/FBAR,Tax Evasion   |   1 Comment

For US taxpayers with Foreign Bank Accounts valued over $10k, a Fincen Form 114 must be electronically filed by June 30 each year. The penalties for failure to file are both civil and criminal and may include: 1) Failure to Report Foreign Bank and Financial Accounts (Form 1040/Schedule B, Part III, 7 (a)) which may […]

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Offshore Voluntary Disclosure Program does not Save Connecticut CEO from Prosecution

January 27, 2015  |   Posted by :   |   OVDP,Tax Evasion,Unreported Income   |   0 Comments

In my book, Offshore Tax Evasion: IRS Offshore Voluntary Disclosure Program I strongly recommended against taxpayers entering the OVDP program due to risk of rejection and criminal prosecution. On 1/22/15, the Ridgefield Press reported that George Landegger, age 77, CEO of Parsons & Whittemore, a pulp mill company which he sold to Georgia Pacific in […]

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Court Upholds Record FBAR Penalties, Exceeding Offshore Account Balance

June 20, 2014  |   Posted by :   |   FATCA/FBAR,Tax Evasion,Unreported Income   |   0 Comments

In the case of Carl Zwerner a $1.69 million undisclosed offshore Swiss Bank account (ABN/AMRO) cost the Florida taxpayer $3.48 million for FBAR (and other) violations (i.e. two times the account value). The jury found Zwerner willful and imposed the FBAR 50% penalty. The Zwerner case confirms: 1. The IRS/OVDP risks (the taxpayer applied, was […]

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New Jersey Man Pleads Guilty In Manhattan Federal Court To Hiding Over $1 Million In Secret Swiss Bank Account

June 06, 2014  |   Posted by :   |   Tax Evasion,Unreported Income   |   0 Comments

Preet Bharara, the United States Attorney for the Southern District of New York, and Shantelle P. Kitchen, the Acting Special Agent-in-Charge of the New York Office of the Internal Revenue Service, Criminal Investigation (“IRS-CI”), announced that VIKTOR KORDASH pled guilty today to willfully failing to file Reports of Foreign Bank and Financial Accounts (“FBARs”) with […]

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IRS Offshore Accounts – Criminal Penalties

April 28, 2014  |   Posted by :   |   Tax Evasion,Unreported Income   |   0 Comments

Criminal Penalties (6 Year Statute of Limitations) 1. Tax Evasion (Willful Evasion of Tax) (lRC Sec. 7201) up to five years in prison Fine: $100,000 (individual) $500,000 (corporation) 2. Obstruct (Impede Tax Collection) (lRC Sec. 7212) up to three years in prison Fine: $5,000 3. Conspiracy to Impede Tax Collection (18 USC 371) separate charges […]

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IRS: FATCA Extended Deadline to 7/1/14

August 23, 2013  |   Posted by :   |   FATCA/FBAR   |   0 Comments

U.S. Treasury extended until July 1, 2014 the enforcement of the new law, Foreign Account Tax Compliance Act (“FATCA”) to give foreign banks more time to comply. FATCA requires foreign banks, insurance companies and investment funds to send the IRS information about American’s offshore accounts worth more than $50,000. Robert Stack, U.S. Treasury deputy assistant […]

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IRS Tax Compliance – Offshore Accounts

June 19, 2013  |   Posted by :   |   Circular 230   |   0 Comments

Under Treasury Department Circular #230 (Rev. 8/11), Title 31 Code of Federal Regulations, Subject A, Part 10 (published June 3, 2011), Section 1021 requires a tax practitioner who knows that the client has not complied with U.S. revenue laws, or made an error or omission in a tax return, to promptly advise the client of […]

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