California Tax Law Blog

Swiss Banker’s Acquittal Still Bad News For U.S. Taxpayers

Swiss Banker’s Acquittal Still Bad News For U.S. Taxpayers

| Nov 13 | FBAR Compliance and Disclosure, Tax Law Blog | No Comments
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It took a federal jury only 90 minutes to reach a not-guilty verdict on Monday in the case of former UBS executive Raoul Weil. The former global wealth-management chief was being tried on conspiracy charges relating to the efforts by UBS and their employees to assist U.S. taxpayers avoid declaring or paying taxes on, their accounts held outside of the U.S.  If you have accounts overseas, the time to file an FBAR is now.  Read More

Swiss Banks Ask DOJ to Ease Amnesty Requirements

Swiss Banks Ask DOJ to Ease Amnesty Requirements

| Nov 11 | OVDI Program, Tax Law Blog | No Comments
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The past few years have been rough for Swiss banks. Several banks have either pled guilty to U.S. crimes or have come to an agreement with the U.S. Department of Justice and agreed to pay fines and other penalties to avoid prosecution. Another way that Swiss banks have been ensuring that they are not criminally prosecuted in the United States is a non-prosecution program. This program provides amnesty to Swiss banks and consequently has been heavily utilized. Since its inception in 2013, approximately one-third of Swiss banks have joined. The crux of the deal is that the Department of Justice will agree to not prosecute the participating Swiss banking entities in exchange for full and total cooperation.

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Web Entrepreneur Charged Over Swiss Bank Account

Web Entrepreneur Charged Over Swiss Bank Account

| Oct 23 | OVDI Program, Tax Law Blog | No Comments
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It seems that every week, we bring you stories about United States taxpayers that have been charged with hiding money in foreign bank accounts. As of recently, taxpayers have, for the most part, shifted away from storing their money in Swiss banks. This is, in large part, due to the major crackdown of Swiss banks in an attempt by the U.S. to destroy any type of secrecy arrangements that foreign institutions may have with their customers. But alas, all of the news about prosecutions and IRS criminal investigations over stashing money in Swiss institutions doesn’t deter everyone.

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Prepare Your Offshore Disclosure Carefully — Especially Where it Involved 5 or More Foreign Informational Returns — Or Else

Prepare Your Offshore Disclosure Carefully — Especially Where it Involved 5 or More Foreign Informational Returns — Or Else

| Oct 21 | OVDI Program, Tax Law Blog | No Comments
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The IRS developed the Offshore Voluntary Disclosure Program to help taxpayers come clean about accounts held in foreign jurisdictions. Because the program is one of administrative grace and not a right of taxpayers, the Service has unfettered authority to administer it as they choose. An update of the Internal Revenue Manual (providing procedural guidance to IRS employees) sheds some light on how applications to be a part of the OVDP are selected for an examination.

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Foreign Banks Directed to Hand Over American Account Info

Foreign Banks Directed to Hand Over American Account Info

| Oct 16 | FBAR Compliance and Disclosure, Tax Law Blog | No Comments
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Orange County taxpayers haven’t been the only folks to line up to take advantage of a voluntary disclosure program offered by the government. Over 100 foreign banking institutions signed up to take part in anti-prosecution agreements with the Department of Justice earlier this year. This was, in large part, a response to the huge settlement between the DOJ and UBS, back in 2009. UBS handed over fines of roughly 780 million dollars and agreed to hand over the names and account information of tens of thousands of its American account-holders.

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Founders of Orange County Company Sentenced to Prison for Tax Evasion

Founders of Orange County Company Sentenced to Prison for Tax Evasion

| Oct 09 | Criminal Tax Representation, Tax Law Blog | No Comments
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If you frequent the David W. Klasing Tax Blog, you know that we strive to report on the most pertinent topics pertaining to tax law in order for you to avoid being caught up in a situation that can land you in prison. Our stories come from all around the country, but last week, an Orange County couple was sentenced to time in prison for the tax evasion activities of their business. This is too close to home and the punishment was too severe to be ignored.

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Beware of FATCA Scammers!

Beware of FATCA Scammers!

| Oct 07 | FBAR Compliance and Disclosure, Tax Law Blog | No Comments
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Last week the IRS made an announcement regarding a new wave of attempts to scam foreign banks into giving out American taxpayer account information. According to the Service, scam artists are contacting officials at foreign banks and impersonating U.S. government officials. They will threaten that the bank is in violation of the FATCA rules and make a demand for certain account records. The United States has come out to set the record straight about this matter and assured foreign institutions that they would not be contacted through an informal telephone call or email if there was an issue with regard to the requirements of FATCA and or the bank’s reporting obligations. Are you dealing with a real IRS criminal investigation, or just a scam?

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Imaginary Company Will Cost Michigan Businessman His Freedom. Don’t Make This Mistake.

Imaginary Company Will Cost Michigan Businessman His Freedom. Don’t Make This Mistake.

| Oct 02 | Criminal Tax Representation, Tax Law Blog | No Comments
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As children, many of us had something imaginary. Whether it was a pet or a friend, we created something from nothing and went about our lives pretending that it existed. What if we were to do that today? How much trouble would it get us into? Michael Stover from Plymouth, Michigan did just that and it turns out that he will get more than just a time-out. If you find yourself facing a similar situation, you should seek out a tax litigation lawyer before it’s too late.

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Brazil Enters Into IGA with the United States

Brazil Enters Into IGA with the United States

| Oct 01 | FBAR Compliance and Disclosure, Tax Law Blog | No Comments
BrazilIGA

Brazil is the latest country to enter into an information-sharing agreement with the United States. Last week, the two nations came together to sign the Intergovernmental Agreement (IGA) and jointly announced the details. What can be gleaned from the announcement is that if you are an American with assets in accounts in Brazil, your financial information will soon be shared directly with the IRS. But the agreement doesn’t end there. If you are a Brazilian national, living in the United States, you are also in the crosshairs, as the IGA will also require the IRS to send financial data on Brazilians back to Brazil’s Finance Ministry. Are you prepared with a criminal tax lawyer?

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Could a Bad Tax Lawyer Land You in Prison? A California Dentist Thinks So.

Could a Bad Tax Lawyer Land You in Prison? A California Dentist Thinks So.

| Sep 30 | Criminal Tax Representation, Tax Law Blog | No Comments
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When we turn on the news and hear of people being arrested and sentenced to lengthy prison sentences, we usually presume that they have committed some sort of disturbing or violent crime against others. And though that is often the case, there are also those who are ordered by a judge to don a colored jumpsuit and be confined in a federal prison even though there are no human victims of their crime. Sadly, a few of these prison inmates may have not even been at fault and simply were taken advantage of. Could a bad tax attorney put you at the center of an IRS criminal investigation?

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