California Tax Law Blog

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
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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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Wine Executive Sentenced to 33 Months In Prison for Tax Evasion

Wine Executive Sentenced to 33 Months In Prison for Tax Evasion

| Sep 25 | Criminal Tax Representation, Tax Law Blog | No Comments
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People generally drink a glass of wine to unwind after a long day or to compliment a fancy meal. But for former WineTasting Network executive Martin Christopher Edwards, it is a delicacy that he won’t be enjoying for a long, long time. For Edwards, it wasn’t the wine that got him in trouble; it was over two years of tax evasion and embezzlement.

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Lithuania Added To Long List Of Inter-Governmental Agreements

Lithuania Added To Long List Of Inter-Governmental Agreements

| Sep 23 | OVDI Program, Tax Law Blog | No Comments
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If the United States were a person, do you ever wonder what they may daydream about? What would the world look like if the U.S. could have everything their way? Well, for international tax purposes, it is conceivable that they would want full disclosure of all American-owned accounts overseas, regardless of the country that they are in. Unfortunately for U.S. taxpayers, the U.S. wouldn’t have to dream that sort of scenario up, it is already happening.

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Taxpayers Beware: Another International Exchange of Information Agreement

Taxpayers Beware: Another International Exchange of Information Agreement

| Sep 18 | OVDI Program, Tax Law Blog | No Comments
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Most middle-aged Americans can remember a time where it was possible to open an account in a foreign country and deposit as much money as desired without attracting much attention. In fact, communication between nations until recently was relatively non-existent. Over the last decade, American tax and law enforcement agencies have taken significant steps in making the world a more connected place, when it comes to communicating foreign account information. The goal of all of this information sharing: to discover those with concealed bank accounts and to catch those who are evading taxes on a worldwide basis. Tax fraud lawyers are paying close attention to this issue.

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Some Banks Bail on Non-Prosecution Agreement – Don’t Be Fooled

Some Banks Bail on Non-Prosecution Agreement – Don’t Be Fooled

| Sep 08 | OVDI Program, Tax Law Blog | No Comments
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It is now no surprise to taxpayers around the world that the United States has trained their sights on not only Swiss banks, but on all foreign institutions that could be helping Americans hide money from the watchful eye of the U.S. government. Recent news of banks pulling out of previously made agreements with the U.S. may give taxpayers who have secret accounts false hope. It is important that you fully understand the risk that you are taking before you decide to do nothing. Read More

Have You Received a Letter From Your Foreign Bank Regarding Required Reporting of Your Account to the U.S. Government Under FATCA? If So, Listen Up!

Have You Received a Letter From Your Foreign Bank Regarding Required Reporting of Your Account to the U.S. Government Under FATCA? If So, Listen Up!

| Sep 02 | FBAR Compliance and Disclosure, Tax Law Blog | No Comments
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Thousands upon thousands of Americans have some amount of money in an account that is deposited with a bank that is outside of the United States. There is certainly nothing per se illegal against keeping your money outside of the U.S. If you have a foreign account, it is probably common for you to receive some regular correspondence from your overseas bank. But watch out, a growing amount of foreign banks are sending out letters that can be precursors of draconian fines or even time in prison on the horizon if you have failed to report the existence of your foreign account on FinCen Form 114 (Previously TDF 90-22.1) and reported the income generated by the foreign account for U.S. income tax purposes. Read More

Small Business Owner Sentenced to 46 Months in Prison

Small Business Owner Sentenced to 46 Months in Prison

| Aug 28 | Criminal Tax Representation, Tax Law Blog | No Comments
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When a business opens its doors to the public, it is expected that they treat their customers and employees fairly and with respect. Employers are required to withhold taxes for their employees and remit that money to the IRS. Then, that money is either credited to the employee’s tax bill or refunded to them in the event of an overpayment.

Most employers take care of this task diligently and without issue. But not every business owner takes the necessary steps to ensure that they are in compliance with the law. Read More

Florida Man Pleads Guilty to Failing to Disclose Foreign Accounts, Faces Prison Time

Florida Man Pleads Guilty to Failing to Disclose Foreign Accounts, Faces Prison Time

| Aug 26 | Criminal Tax Representation, FBAR Compliance and Disclosure, OVDI Program, Tax Law Blog | No Comments
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Many of us can think back to a time where the term “Swiss bank” meant secrecy and represented a haven for tax avoidance. But over the past decade, the benefits of storing money have slowly, but surely dissipated. And though we may all know this, there are still some American taxpayers who may not quite understand that the game has changed and that the United States government is serious when they tell you to report your foreign accounts or go to jail.

Bernard Kramer, a Florida resident, pled guilty this week on charges related to conspiracy to defraud the United States and willfully failing to declare offshore accounts on his income taxes. Read More

Serbia Showing Some Hostility Toward FATCA Requirements

Serbia Showing Some Hostility Toward FATCA Requirements

| Aug 21 | OVDI Program, Tax Law Blog | No Comments
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In the recent past, we have brought several stories to you detailing how numerous countries have decided to participate in the Foreign Account Tax Compliance Act, also known as FATCA. Cooperation from other countries has come in various forms. Some countries have opted to enter into Intergovernmental Agreements with the U.S. and share information between nations while other countries have simply allowed, encouraged or even required their financial institutions to comply with the reporting provisions of FATCA. But not all countries are completely on board with the demands of the United States. Read More

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