Category Archives: Offshore Bank Accounts

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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