We live in a society that tries hard to find technological solutions to problems. This attempt is not always successful, but it has deep roots in the culture. In tax compliance, one way in which the search for a technical solution is present is the Automated Underreporter Program (AUP). The […]
Category: Tax Evasion
Bankruptcy is by no means a sure-fire way to evade the IRS. An octogenarian widow of a Texas billionaire is finding this out now. In this post, we will discuss the case of Caroline “Dee” Wyly, against whom the Internal Revenue Agency is seeking a $386 million tax fraud penalty. […]
Tax law is filled with abbreviations. IRS of course stands for Internal Revenue Service. OIC stands for offer in compromise. FBAR stands for Report of Foreign Bank and Financial Accounts (now also known as FinCEN form 114) and so on. The newest abbreviation is CRS. (No, not CVS, the national […]
The IRS has served John Doe summonses to a number of banks in Belize, seeking information about American account holders, as the U.S. federal government continues its onslaught against offshore tax evasion. Long known as a tax haven, Belize has been a popular destination for wealthy individuals seeking to avoid […]
In the first part of this post, we noted that the Criminal Investigation (CI) division of the IRS is involved in the investigation of several financial crimes that do not directly involve tax law. These crimes include fraud, money laundering and violations of the Bank Secrecy Act. In our September […]
Sometimes a change makes so much sense that you wonder why it didn’t happen earlier. Many taxpayers with offshore accounts would agree this is the case with the recent adjustment of the filing date for the FBAR form. In this post, we will inform you about the change, under which […]
One of the threads we are following in this blog is the IRS whistleblower program. Whistleblowers are people who alert the IRS to non-compliant taxpayers. Typically, in a whistleblower scenario, this taxpayer will be the whistleblower’s employer. The law allows for financial awards for whistleblowers who meet certain criteria. But […]
In the first part of this post, we began discussing how federal regulators use non-prosecution agreements (NPAs) and deferred prosecution agreements (DPAs) to resolve various legal compliance concerns. In the tax community, this has particularly been the case with offshore accounts. Indeed, for nearly two years, the Tax Division of […]
In recent years, increased U.S. enforcement of offshore account reporting requirements has not only affected individual taxpayers. Foreign financial institutions have also been deeply affected. Swiss banks, historically a haven for undisclosed accounts, have come under particular scrutiny. And so it was no surprise that Forbes reported this week on […]
Due to budget cuts in recent years, the IRS has downsized its employee headcount significantly. But the agency’s pursuit of criminal investigations has been going up, not down. This is a story we’ve been following for some time. We discussed it at length a couple of years ago in an […]