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National Law Firm For Foreign Bank Account Disclosure

German Investigation of Credit Suisse The United States has recently launched investigations of banks such as HSBC and UBS, preparing to take civil and criminal action against Americans with offshore accounts who fail to pay required U.S. taxes. Germany appears to be following the U.S. lead regarding enforcement in the […]


Foreign Bank Accounts Lawyer

It is not illegal for U.S. citizens to have foreign bank accounts. There are many legitimate reasons for a U.S. taxpayer to maintain a foreign bank account, including confidentiality, portfolio hedging and asset protection. However, U.S. taxpayers who have offshore or foreign accounts must adhere to certain requirements. They must […]


3 FAQs about the Abusive Return Preparer initiative

The Internal Revenue Service (IRS) is cracking down on fraudulent tax preparer services. The federal agency initiated 252 investigations in 2016 alone, searching out any individual or business that it believes was conducting fraudulent practices while preparing taxes. 72.8 percent of these investigations resulted in incarceration. Although these efforts are […]

Tax Crimes

What is FinCEN?

FinCEN. It sounds like something out of a Hollywood plot line about a secret government agency running clandestine missions that are kept out of the purview of the general public. Is the truth that far from reality? FinCEN is not an unknown entity. United States taxpayers with foreign accounts are […]

Offshore Accounts/International Tax Disputes

Return Preparer Penalties

Those who prepare income tax returns — CPAs, tax attorneys, Enrolled Agents and non-enrolled tax return preparers — often find themselves the subject of a civil audit or even worse a criminal investigation relating to their tax preparation work. At Brown, PC, we have extensive experience representing tax preparers. Our […]