201903.15
0

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
0

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
0

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
0

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 —…

201903.03
0

FBAR Regulations (2019) – Courts Split on IRS Willful Penalty Maximum

FBAR Regulations (2019) – Courts Split on IRS Willful Penalty Maximum When congress increased the penalties for FBARs (Report of Foreign Bank and Financial Accounts, aka FinCEN 114) – the regulations ‘Regs’ were not updated to coincide with the new law. Common Questions include: What is the FBAR? What is a Regulation? What is an…

201902.25
0

U.S. Citizens Living Abroad File IRS Tax Returns, FBAR and FATCA

U.S. Citizens Living Abroad File Tax Returns, FBAR, and FATCA, which required them to disclose overseas (and U.S.) income, assets, accounts and investments. A common misconception for U.S. Citizens and Legal Permanent Residents (Green-Card Holders) is that moving abroad will free them from the shackles of the US tax system. Unfortunately, it does not work…

201902.17
0

Eligible Deferred Compensation Items & U.S. Expatriation Tax Laws

Eligible Deferred Compensation Items & U.S. Expatriation Tax Laws This is a common question we receive from clients re: Expatriation, so we wanted to try to explain it in plain (relatively plain) “English.”  When it comes time to expatriation from the U.S. and the relinquishing/renouncement of your U.S. Citizenship or Green Card Status – you…

201902.11
0

Non-Dually Licensed Tax Attorneys Put Your Confidentiality at Risk

Dually Licensed Attorney/EA Helps Protect Client Confidentiality As we approach the thick of tax season, our blog entries get less frequent — but we thought this was a very important topic for our clients around the world who are being misled by other attorneys and firms to take the time to read. IRS offshore compliance enforcement…

201902.11
1

False Tax Return, Unreported Foreign Income & No FBAR – Jail & Fines

False Tax Return, Unreported Foreign Income & No FBAR – Jail & Fines In late 2018, Israel Birman pled guilty to filing a false tax return. One of the main components of the crime was the failure to report foreign accounts on the FBAR. Specifically, “According to court documents, between 2006 and 2014, Israel Birman…

201902.05
0

GILTI – What You Must Know About Global Intangible Low-Taxed Income

GILTI – What You Must Know About Global Intangible Low-Taxed Income GILTI is a perfect example of what is wrong with U.S. tax law. GILTI refers to Global Intangible Low-Taxed Income. But, GILTI is not limited to Intangible or Low-Taxed Income. And, as with FATCA, while the goal is to reduce offshore tax evasion and…