201903.18
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Deferred Prosecution Agreements, Offshore Disclosure & Dual-Citizens

Deferred Prosecution Agreements, Offshore Disclosure & Dual-Citizens Deferred Prosecutions Are Dangerous to Offshore Voluntary Disclosure When a person submits to U.S. Offshore Voluntary Disclosure, it is important that they are properly counseled on the impact of a disclosure, and how it may impact their exposure — both in the U.S. and abroad. Offshore Disclosures are…

201903.15
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Israeli Bank Gets Penalized $195M DOJ Offshore Tax Fraud Penalty

Israeli Bank Gets Penalized $195M DOJ Offshore Tax Fraud Penalty The U.S. DOJ deferred prosecution agreements are starting to really bear fruit.  Recently, Mizrahi-Tefahot Bank Ltd., agreed to a penalty in the amount of $195M. Common Questions What was the Scam?  What is a Hold-Mail Agreement? What is a Deferred Prosecution Agreement? Deferred Prosecution Agreement?…

201903.14
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Beware of IRS Special Agents Asking About Offshore Bank Accounts

Beware of IRS Special Agents Asking About Offshore Bank Accounts IRS special agents are a sneaky bunch. The agents move pretty stealthily through the pre-investigation face in order to compile enough information to determine whether or not they want to further investigate and “interview” you.   This may mean interviewing your Bank, CPA, or other…

201903.11
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5 Common Questions About Filing FBAR for the First Time

5 Common Questions & Mistakes About Filing FBAR for the First Time The FBAR is the FinCEN 114 “Report of Foreign Bank and Financial Account Form.” It is used to report foreign accounts to the U.S. Government — if you meet the threshold requirements for doing so. Common Questions we receive about the FBAR: Does…

201903.04
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Schoolteacher Disputes IRS Willfulness – Appeals $800K in FBAR Fines

Schoolteacher Disputes IRS Willfulness – Appeals $800K in FBAR Fines Mindy P. Norman is a schoolteacher in New York. She held more than $1,600,000 in foreign bank accounts. She played hooky from the IRS, and failed to report the accounts. The IRS caught her in the act, discovered the accounts, and gave her detention —…