Tag Archives: OVDP

Offshore Tax Evasion and the City of London (UK)

June 19, 2017  |   Posted by :   |   Tax Evasion   |   0 Comments

In an explosive article for the UK Independent, author Paul Holden poses a rhetorical question, “David Cameron vowed to crack down on offshore tax evasion so why has it disappeared from the Tory Manifesto?” Previously in 2016, Italian Mafia expert and author Roberto Saviana labeled the UK “the world’s most corrupt country” citing the vast […]

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IRS OVDP (7/1/14) Risks & Perils – Part 3

March 24, 2016  |   Posted by :   |   OVDP   |   0 Comments

If you have been reading my previous newsletters you would know that I have grave misgivings about the IRS/OVDP. The reasons are as follows: 1) Under IRC sec 7525 there is no attorney-client privilege for criminal tax evasion (which means that if the OVDP submission is not accepted, the taxpayer is later ruled ineligible, or […]

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IRS Offshore Voluntary Disclosure Program – 2016

February 22, 2016  |   Posted by :   |   OVDP   |   0 Comments

As of 7/1/14 the IRS changed their 2012 Offshore Voluntary Program in a stealth manner which greatly increased both the costs and the risks. Effective 7/1/14, the OVDP requires: 1) Payment up-front with the OVDP Application of all Tax, Penalty and Interest due which includes the Offshore Penalty (Title 26 Misc. Penalty), which is either […]

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IRS Offshore Voluntary Disclosure Program

September 04, 2015  |   Posted by :   |   OVDP   |   0 Comments

Criminal Tax Defenses (Issues) For those U.S. taxpayers who voluntarily entered the IRS Offshore Voluntary Disclosure Program, they waived numerous rights, including: 1. The 5th Amendment right against self-incrimination; 2. A 4th Amendment right to be secure in their persons, papers and property from “unreasonable searches and seizures”; 3. A statute of limitations defense to […]

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Revenues surge as global crackdown on tax evasion gathers pace

August 11, 2015  |   Posted by :   |   OVDP,Tax Evasion   |   0 Comments

As stated in the article below, $10 trillion is still being hidden in offshore financial centers. Only a fraction of these tax cheats have come forward to declare their assets (despite the claims in the article). In the US less than 50,000 taxpayers have disclosed their offshore accounts under the IRS Offshore Voluntary Disclosure Program […]

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Offshore Tax Evasion: IRS Tax Audit

January 08, 2015  |   Posted by :   |   Tax Evasion   |   0 Comments

For those US taxpayers committing offshore tax evasion i.e. not reporting foreign income, not disclosing offshore accounts, they face a myriad of IRS tax audit issues: Civil and Criminal Penalties, and a myriad of Statute of Limitations. The IRS Civil and Criminal Penalty Issues include the following: Civil Penalty Issues 1. Civil Tax Fraud (75% […]

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IRS Hikes Offshore Account Penalty To 50% For Bank Leumi, Sovereign, 10 Others

January 06, 2015  |   Posted by :   |   OVDP   |   0 Comments

By Robert W. Wood, Forbes.com The IRS has updated its list of so-called bad foreign banks where offshore accounts trigger a 50% (rather than 27.5%) penalty in the Offshore Voluntary Disclosure Program (OVDP). The IRS added Sovereign Management and Legal, Ltd., plus certain branches of Bank Leumi. Neither addition should come as a surprise. Both […]

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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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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 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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