We have previously written on the topic of the “Quiet Disclosure” alternative for complying with U.S. offshore reporting requirements: IRS Collected $5.5 Billion From OVDI, But According to GAO, May Be Missing Billions More? IRS Cracks Down on "Quiet Disclosures" Quite Disclosure" Caught - DOJ Files To Collect 50% FBAR Penalty! Under this alternative,…
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Criminal Exposure for Late Filing Even If Qualify under FAQs!
In a recent appellate case, US v. Simon, 7th Circuit Court of Appeals, August 15, 2013, the taxpayer filed required FBAR’s late, using the filing procedure allowed for late filings under the 2009 OVDI FAQ. Nonetheless, the court found that the FAQ relief from civil penalties was not a bar to the government asserting criminal…
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Criminal Score Card Not Good For Offshore Account Holders!
In our previous post UBS Criminal Casualties, so Far and More Guilty Pleas Over Offshore Accounts in the Works! regarding the U.S. and Swiss Reach a Deal on American Tax Evaders, the IRS hunt for offshore income and accounts continues unabated. Now in the wake of H. Ty Warner, the billionaire creator of Beanie Babies plush toys, pleaded guilty last…
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Are Your Ready For The IRS' New Rigid IDR Enforcement Procedures?
On June 18, 2013, the Acting LB&I Commissioner issued a directive (LB&I Control No: LB&I-04-0613-004) to LB&I employees announcing that for all IDRs issued after June 30, 2013: The examiner must identify and state the issue that has led the examiner to request the information included in the lDR. The examiner must discuss the lDR…
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