Category Archives: FBAR

To avoid penalties, a U.S. person with offshore assets will have to disclose those assets and the related income to the IRS, as well as pay taxes on foreign income.

Although experienced practitioners knew the IRS position, it was formally …

Will my foreign real estate (property) be included in the calculation for the 27.5 OVDP FBAR penalty? One issue that comes up often is how foreign real estate effects how much our clients would owe under the 2012 IRS Offshore Voluntary Disclosure Program (known as the 2012 OVDP or IRS amnesty for offshore bank accounts […]

Recently The Fourth Circuit Court of Appeals made a controversial decision regarding willfulness as it applies to FBAR obligations. United States v. Williams, No. 10-2230 (4th Cir. July 20, 2012). This ruling may add risk to opting out of the Offshore Voluntary Disclosure Program or disclosing foreign bank accounts late without entering into the Offshore […]

In a Tax Notes Today report of statements made at the Eastern Pennsylvania Working Together Conference in Malvern, PA, Jason Kuratnick, IRS Associate Area Counsel (Philadelphia), Small Business/Self-Employed Division is reported to have said. The IRS may send a warning letter in lieu of asserting penalties for failure to file a Form TD F 90-22.1, […]

Switzerland’s oldest bank was indicted back on February 02, 2012 for conspiring with U.S. taxpayers and others to hide more than $1.2 billion in secret offshore foreign banks and financial accounts and the income they generated from the IRS. It was the first time in history that an overseas bank was indicted by the United […]

Yesterday, a federal grand jury in San Jose, California, indicted Ashvin Desai of San Jose on three counts of tax evasion on $1.3 million in unreported interest income, two counts of willfully aiding the preparation of materially false tax returns and three counts of failing to file Reports of Foreign Bank and Financial Accounts (FBARs), […]

According to an exclusive report by Reuters, U.S. authorities are focusing on Bank Hapoalim, Bank Leumi, and Mizrahi-Tefahot. The three Israeli banks have Swiss outposts and were sent a letter dated August 31, 2011 from Deputy Attorney James Cole of the DOJ giving them until September 23, 2011 to produce broad statistical information on their […]