All posts by Abajian Law

Another Swiss executive joins the growing list of Swiss bankers and executives who have been charged with allegedly aiding wealthy Americans in tax evasion. Raoul Weil, former head of UBS’s global wealth management business and a Swiss Citizen, was arrested in Bologna on October 19. In November 2008, when he was still working with UBS, […]

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Vic Abajian, attended the annual Tax Controversy Institute on October 22, 2013. This is his 12th year attending. The institute brings together sophisticated tax practitioners from the federal government, judiciary, and private practice to discuss and debate the procedures, policies, and strategies that are involved in resolving difficult tax controversy issues. Future challenges of the […]

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United States’ government continues to track down tax evaders with offshore accounts under FATCA (Foreign Account Tax Compliance Act), which not only requires individuals to report their financial accounts held outside of the United States, but also compels foreign financial institutions to report to the Internal Revenue Service (IRS) about their American clients. Ty Warner, […]

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The IRS and Swiss banks have formed a deal that could expose Americans who hid their assets in Swiss banks to avoid tax liability. The long running dispute between the IRS and Switzerland might finally come to a resolution with the Swiss banks complying with FATCA (Foreign Account Tax Compliance Act). Those with offshore accounts […]

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In 2008, a former employee of the Swiss global financial services institution, UBS, made a statement that the Swiss bank was actively helping U.S. Citizen Accountholders to evade US tax liability. This sparked the United States law called FATCA (Foreign Account Tax Compliance Act), which not only requires individuals to report their financial accounts held […]

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Lebanon has long been hailed as “Switzerland of the Middle East” because of its Banking Secrecy Law that was passed in 1965. This law restricted banks from revealing client names or account information to any individual or authority. However, with the IRS searching for American tax dodgers abroad; it is now becoming increasingly difficult to […]

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The Swiss government will consider ways to allow the country’s banks to hand over information to U.S. authorities after parliament blocked the bill that would have allowed the banks to dissolve secrecy laws. The lower house voted two-to-one against the bill, even though the upper house had backed it. The bill is the result of […]

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On June 7, 2013, Switzerland signed a Memorandum of Understanding (MOU) with the US on interpretations regarding US Foreign Account Tax Compliance Act (FATCA). The Swiss Federal Department of Finance stated: “Within the scope of the negotiations, both sides agreed to set out individual interpretations of a technical or administrative nature in a MOU.” Legislation […]

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A common question that many taxpayers have is whether closing a foreign bank account will help with any FBAR obligations or reporting requirements past or present. Even if an account is open for just one day, there is an FBAR filing requirement if the aggregate value of the account or accounts exceeds $10,000. For example, […]

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United States v. Canale is another recent example of the possible outcome for U.S. taxpayers who do not disclosure income from foreign bank accounts and the fact that the account existed. Participation in the IRS Offshore Voluntary Disclosure Program (OVDP) would have resulted in no jail time and a far lesser monetary penalty. Michael Canale, […]

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