Another Plea Involving Offshore Accounts

DOJ Tax has this press release, Tennessee Couple Plead Guilty to Tax Crimes , cryptically reporting a plea by two taxpayers, husband and wife, to two counts of willful failure to file income tax returns ( Section 7203 ). In relevant part, the press release says: Additionally, during the years in...

Reporting Specified Financial Assets and Form 8938

U.S. taxpayers with assets overseas and their advisers should be mindful of new Form 8938, Statement of Specified Foreign Financial Assets , as they prepare the taxpayers' federal income tax returns for 2011. Temporary Regulations issued in December 2011 state that, with certain exceptions, Form...

Convictions of Mail Fraud, False Claims and Conspiracy; Use of Offshore Accounts

According to a DOJ Press Release, Curtis Morris and Richard Kellog Armstrong were convicted of "for mail fraud, filing false claims against the United States and conspiracy to file false claims against the United States." "Morris was found guilty of three counts of mail fraud, seventeen...

Convictions of Mail Fraud, False Claims and Conspiracy; Use of Offshore Accounts

According to a DOJ Press Release, Curtis Morris and Richard Kellog Armstrong were convicted of "for mail fraud, filing false claims against the United States and conspiracy to file false claims against the United States." "Morris was found guilty of three counts of mail fraud, seventeen...

Another UBS Depositor Pleads Guilty

Yesterday, Humberto Gomez pled guilty, according to a DOJ Tax press release, here [the link is not yet available; I will post the link when I have it]. ... The tax loss seems low. The press release says: "For the years 2006 and 2007, the criminal tax loss associated with the Bullrush account...

Pastor Going to Trial for Tax Charges Predicted Jesus Would Come On May 27

I have previously blogged on Ronald Weinland. See Controversial Pastor, Self Proclaimed Prophet, Indicted re Income from Church Offerings and Offshore Accounts (11/21/11), here . My impression from afar is that he is just a charlatan (see here ) in the guise of a religious person. Just in case he has...

New Indictment of U.S. Tax Return Preparers & Enablers re Offshore Bank & Related Activity

In a First Superseding Indictment, here , filed June 14, 2012 in CD CA, three principals of a tax return preparation service, United Revenue Service ("URS") were indicted. The DOJ Tax Press Release is here, Three Tax Return Preparers Charged With Helping Clients Evade Taxes By Hiding Millions...

FATCA (Foreign Account Tax Compliance Act) Proposed Regulations

The most recent proposed Foreign Account Tax Compliance Act (FATCA) regulations are designed to lighten the due diligence and compliance burden on foreign financial institutions and U.S. withholding agents, especially with respect to high value accounts. The Foreign Account Tax Compliance Act (FATCA...

Further Guidance on Foreign Financial Asset Reporting

[ Editor's Note: This narrative is derived from Rhoades & Langer, U.S. International Taxation and Tax Treaties, Chapter 9 (Matthew Bender) .] Virtually all individual taxpayers (and certain entities called "specified domestic entities") are required to report their financial assets...

Defendant Waives Attorney-Client Privilege by Asserting Reliance on FBAR Advice Defense

In United States v. Kerr, 2012 U.S. Dist. LEXIS 98836 (D AZ 2012) , a case with two U.S. taxpayers and their lawyer as defendants, the court held that the indicted U.S. taxpayers' claims of reliance constituted a waiver of their attorney-client privilege with respect to communications with their...

Suellen Wolfe on Offshore Voluntary Disclosure Initiatives

By Suellen Wolfe, J.D., LL.M.* The Internal Revenue Code requires U.S. taxpayers to report income and pay taxes on worldwide income. [ IRC §§ 61 , 861 , 862 , 863 , 864 , 865 . See also, IRS Publication 17 at Part Two, 5 (2011).] Intentionally failing to report income earned on financial...

Reporting Specified Financial Assets and Form 8938

U.S. taxpayers with assets overseas and their advisers should be mindful of new Form 8938, Statement of Specified Foreign Financial Assets , as they prepare the taxpayers' federal income tax returns for 2011. Temporary Regulations issued in December 2011 state that, with certain exceptions, Form...

How Many Swiss Banks Will Meet Upcoming Deadline to Participate in Justice Department’s Tax Amnesty Program?

New Year’s Eve Day is the deadline for Swiss Banks to notify the U.S. Justice Department that they are seeking non-prosecution agreements to resolve past cross-border criminal tax under the Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks. The program was announced several...

China’s Top Leaders Have Secret Offshore Accounts, ICIJ Reports

Close relatives of China’s top leaders have secret offshore companies in tax havens that help shroud the Communist elite’s wealth, according to the International Consortium of Investigative Journalists. The group said it based its findings on a leaked cache of documents. According to the...

DC Court Rejects Bankers Attack on FATCA Regs

In Fla. Bankers Ass'n v. United States Dep't of Treasury, 2014 U.S. Dist. LEXIS 3521 (D.D.C. 2014), here , the court sustained the IRS regulations "the regulations requir[ing] U.S. banks to report the amount of interest earned by accountholders residing in foreign countries." The...