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Offshore Accounts/International Tax Disputes Archives

IRS Expands List of Foreign Facilitators

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 ongoing Offshore Voluntary Disclosure Program (OVDP), individuals with one or more accounts at a bank included on this list must pay an increased offshore penalty of 50%, rather than the usual 27.5% that has been required since 2012.

Two U.S. Return Preparers Sentenced for Enabling Offshore Tax Evasion

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, was sentenced to 50 months.

District Court Upholds FBAR Penalties but Scolds IRS for Misleading Taxpayer

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 void.

IRS Focuses on Southeast Asia in Continuing Offshore Crackdown

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 when those Swiss banks came under criminal investigation.

Several More Swiss Banks to Turn Information Over to US

Rothschild Bank AG and Banca Credinvest SA are the two latest Swiss Banks to settle with U.S. authorities as part of the Department of Justice's ongoing Swiss Bank Program. In exchange for non-prosecution agreements, the banks will pay fines and turn over detailed information about their American clients.

IRS Issues John Doe Summonses to Several More Banks

At an annual Offshore Alert conference, the director of the IRS offshore voluntary compliance initiative revealed that the IRS recently issued John Doe summonses to seven more foreign private banks. While he did not reveal which banks the summonses were issued to, he did say that they were not limited to Switzerland.

Swiss Banks Trying to Force U.S. Clients to Disclose

Facing billions of dollars in potential fines at the hands of U.S. authorities, Swiss banks are scrambling to convince their American clients to voluntarily disclose their accounts to the IRS.

Dozens of Indicted Swiss Bankers Still at Large

As the Department of Justice continues its efforts to prosecute individuals involved in offshore tax evasion, approximately two dozen indicted Swiss bankers remain fugitives in Switzerland.

FATCA to Face Legal Challenge in the United States

The Foreign Account Tax Compliance Act (FATCA), a U.S. law passed in 2010 that requires foreign financial institutions to exchange information with the IRS about American account holders, is set to face challenges in both the courts and in Congress.

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