Category Archives: Offshore Bank Accounts

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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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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The Justice Department announced on April 30 that a federal court had authorized the Internal Revenue Service to serve a “John Doe” summons on U.S. taxpayers who may have foreign bank accounts at Canadian Imperial Bank of Commerce’s First Caribbean International Bank (FCIB). The IRS uses such summons to obtain information about possible violations of […]

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Mary Estelle Curran, 79, pleaded guilty on January 8, 2013 to using foreign bank accounts to hide more than $42 million from the IRS. This is one of the largest cases in the continuing U.S. crackdown on offshore tax evasion. Federal authorities with the Justice Department said Curran failed to declare income from 2001-2007 when […]

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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 […]

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The IRS launched its first offshore voluntary disclosure program in 2009. Since then, the program has been reintroduced in 2011 and again in 2012 following strong interest. The IRS has collected more $5 billion in back taxes, interest and penalties from over 33,000 taxpayers who have disclosed their offshore accounts under the first two programs. […]

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Wegelin & Co, the oldest Swiss private bank, announced on January 3rd it would be closing after more than 2 ½ centuries. This closure is following its guilty plea to charges of helping Americans evade taxes through secret accounts. It is the first foreign bank to plead guilty to U.S. tax charges. The bank admitted […]

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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 […]

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