Did you Join OVDP? You’d Better Still be in Tax Compliance!

The Internal Revenue Service (IRS) has now expanded its compliance campaigns and included “post Offshore Voluntary Disclosure Program compliance” on the list. On July 19th, the IRS through its Large Business and International (LB&I) Division announced six new “compliance campaigns” for taxpayers. Significantly, one of these campaigns targets taxpayers who had entered an Offshore Voluntary Disclosure Program (OVDP) … Continue reading Did you Join OVDP? You’d Better Still be in Tax Compliance!

A Dangerous Game: Jail Time for Inherited Foreign Accounts

You may remember my earlier blog post detailing the unenviable case of the wealthy New York Seggerman family which had undisclosed offshore bank accounts inherited from their father. Instead of coming clean and revealing the existence of the accounts to the US Internal Revenue Service (IRS), four of the Seggerman siblings created even more secret … Continue reading A Dangerous Game: Jail Time for Inherited Foreign Accounts

Dubai (and Singapore) – Now IRS Targets for Offshore Investigations

Americans in Dubai / Singapore – If you are not tax compliant, time is really running out.  As reported by Bloomberg on March 8th, an official with the Internal Revenue Service (IRS) Criminal Investigation (CI) unit announced at a Washington DC Federal Bar Association event that CI is considering Dubai and Singapore as its "next … Continue reading Dubai (and Singapore) – Now IRS Targets for Offshore Investigations

It’s Finally Here: The IRS Bible for Voluntary Disclosures

As many will remember, the Offshore Voluntary Disclosure Program (OVDP) closed on September 28th with the promise that the Internal Revenue Service (IRS) would issue new guidance on voluntary disclosures made after that date.  The guidance just arrived in the form of a 5-page Memorandum by Kristen B. Wielobob, Deputy Commissioner for Services and Enforcement, … Continue reading It’s Finally Here: The IRS Bible for Voluntary Disclosures

Newest Targets: “Enablers” and “Cryptocurrencies”

Over the summer, I blogged about the newly formed “Joint Chiefs of Global Tax Enforcement”, or the “J5”, for short.  Five countries form this international coalition: Australia, Canada, the Netherlands, the United Kingdom, and the United States.   The goal of the J5 is to combat transnational tax crime through increased collaboration; in other words, these … Continue reading Newest Targets: “Enablers” and “Cryptocurrencies”

Too Little, Too Late: Fixing the Fraudulent Tax Return

Sometimes an individual will come to me with a pesky problem – they have filed a tax return, but it fraudulently omitted income. Typically, a lot of income.  Typically, from foreign sources.  Always, in hopes the omission will go unnoticed by the IRS.  The thinking is along the lines that since the omission involves foreign … Continue reading Too Little, Too Late: Fixing the Fraudulent Tax Return

Can You Claim a Refund of Your “Willful” FBAR Penalty?

Below is a copy of my post as it appeared (May 21 2018) on my former blog "Let's Talk About US Tax" hosted by AngloInfo. We had a very interesting case decided May 16 2018 when a district court in Texas granted Dominique Colliot’s motion for summary judgment (United States, v. Dominique G. Colliot). The … Continue reading Can You Claim a Refund of Your “Willful” FBAR Penalty?

The Unreported Offshore Account – Still Alive After Death & Plaguing Executors and Heirs

My blog post reproduced below was originally posted on AngloInfo "Let's Talk About US Tax" Posted on October 12, 2015 by Virginia La Torre Jeker J.D., When someone dies owning an unreported financial account, the heirs and executors of the estate are faced with a serious problem. First, assuming there is undeclared income earned with respect to the … Continue reading The Unreported Offshore Account – Still Alive After Death & Plaguing Executors and Heirs