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The most recent answer from the Court of Appeals for the First Circuit is yes. Why can’t you claim a Fifth Amendment privilege against self-incrimination? The answer is the required records exception, which we will discuss in this post. What is the background? The Bank Secrecy Act regulates offshore banking. […]
Category: Offshore Accounts/International Tax Disputes
Staying abreast of changes in reporting requirements on foreign accounts has been a significant agenda item for anyone who works in the banking field. The signature authority rules have even resulted in overlapping requirements. Proposed regulations would clarify some of the rules for filing Reports of Foreign Bank and Financial […]
Going through the prompts on Turbo Tax is straightforward until you reach the question about whether you have a foreign bank account. If you answer yes, you need to understand that the failure to disclose could open you to serious civil penalties. You can no longer file the Report of […]
The Department of Justice announced the conviction of an Alaskan doctor who used secret accounts in Costa Rica to hide assets from his wife, as well as to evade U.S. taxes. At his sentencing next March, he faces a maximum of 20 years imprisonment. He could also be forced to […]
Senator Rand Paul and a group of American expatriates suffered a huge setback in their attempt to overturn the Foreign Account Tax Compliance Act (FATCA), as the judge denied their motion for preliminary injunction, saying that they lack standing for the suit and are unlikely to succeed on the merits. […]
Over the summer, the IRS continued its fight against offshore tax evasion by reaching nonprosecution agreements with dozens of Swiss banks, bringing the total list of “facilitators” to nearly fifty. This list should continue to grow over the next few months. As part of the new reforms made to the […]
The Department of Justice announced that a father and son team of tax return preparers have been sentenced for conspiring with clients to prepare false tax returns omitting the clients’ foreign financial accounts or foreign income. David Kalai has been sentenced to serve 36 months, while his son, Nadav Kalai, […]
On July 31, 2015, the President signed into law H.R. 3236, the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015. Buried in the bill are some important changes to due dates for returns, including FinCen Report 114 (FBAR). Starting with the 2016 tax year, the due date […]
The U.S. District Court for the Western District of Washington has upheld FBAR penalties of $10,000 for tax years 2005 through 2008, but admonished the IRS for what it said was “arbitrary” and “capricious” conduct. As a result, the court ordered that any additional interest or late payment penalties are […]
As the U.S. government’s much publicized crackdown on Swiss banks continues, they may be turning their focus to Southeast Asia, where a Singaporean asset-management firm has fallen under criminal investigation. The firm is suspected of accepting transfers from U.S. taxpayers who were forced to shut down their undeclared Swiss accounts […]