Due Diligence
Posts Tagged tax amnesty lawyer
Indian Business Man Prosecuted For Unreported HSBC India Account (FBAR Post)
Posted by admin in Tax, White Collar Criminal on March 3, 2013
by Brian Mahany Although all the media attention on unreported foreign accounts appears to focused on Switzerland, the Justice Department and IRS continue to look worldwide for U.S. taxpayers with undeclared offshore accounts. According to a press release from the United States Attorney’s Office, Sameer Gupta pleaded guilty last week to one count of tax [...]
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Is IRS To Blame For Huge FBAR Noncompliance Problem?
by Brian Mahany We read about 2 dozens articles each week on offshore reporting, FBARs and the looming FATCA implementation. The rules for these programs are slow in coming and plenty of confusion abounds. Public awareness remains quite low. In fact, most of the clients that come to us never knew they needed to report [...]
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Switzerland Inks Disclosure Agreement With IRS – FATCA Post
by Brian Mahany Ever since the Department of Justice brought criminal charges against Swiss banking giant UBS, we have speculated on when Switzerland’s reputation for banking secrecy would finally fall. Over the last few years, the IRS and DOJ have teamed up to prosecute several Swiss bankers and their clients – Americans with unreported foreign [...]
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Swiss Bank Wegelin Pleads Guilty To Helping Americans Hide Offshore Accounts
by Brian Mahany Switzerland’s oldest private bank appeared in a Manhattan federal courtroom yesterday through one of its managing directors and pleaded guilty to helping Americans hide offshore accounts from the IRS. The United States has pursued other foreign banks but never has it actually indicted a bank. As part of the guilty plea, Wegelin [...]
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Unreported Foreign Accounts – “Should I Just Close The Account And Hope I Don’t Get Caught?”
by Brian Mahany “Should I just close my foreign account and hope I don’t get caught?” We frequently get asked this question. With the penalties so high for unreported offshore accounts, many taxpayers are tempted to simply close the account and transfer their money back to the United States. That may sound like a great [...]
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Swiss Banker Cooperating With IRS, More Prosecutions Likely
by Brian Mahany Recent court proceedings suggest a former Credit Suisse banker may be cooperating with the IRS. Christos Bagios was charged last year with felony conspiracy to defraud the government. Bagios was employed by UBS and later by Credit Suisse Private Advisors. Prosecutors say that he helped American clients hide their money in Swiss [...]
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Isle of Man, Jersey & Guernsey To Sign FATCA Accord With the IRS
by Brian Mahany The crown dependencies of Jersey, Guernsey and Isle of Man are working to shed their reputation as tax havens catering to those who seek to evade tax. All three island states have recently agreed to sign agreements with the United States Treasury in anticipation of the upcoming implementation of FATCA, short for [...]
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IRS Pays $104 Million Whistleblower Award… To Convicted Banker! Banking Secrecy Is Dead!
by Brian Mahany Meet Bradley Birkenfeld. Bradley is a disgraced former Swiss banker that spent about 2 and a 1/2 years in prison for helping Americans evade taxes and hide their money in Swiss accounts. He is out of jail now and is getting a check from Uncle Sam for $104 million. What did he [...]
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Feeling Lucky? Pros and Cons of 2012 OVDI Tax Amnesty
by Brian Mahany Clint Eastwood had many memorable lines as Inspector Callahan in Dirty Harry. One of my favorite lines was “I know what you’re thinking. Did he fire six shots or only five? Well, to tell you the truth, in all this excitement I kind of lost track myself. But being as this is [...]
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Government’s Appeal of FBAR Penalty Loss Headed to Hearing
by Brian Mahany For the few lawyers that extensively help taxpayers with offshore reporting and FBAR problems, the case of United States v. J. Bryan Williams decided in 2010 was a watershed moment. For those not familiar with the case, Bryan Williams was convicted of tax evasion and conspiracy to defraud the IRS back in [...]
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