May 2014

Crimes Under the IRC – Part 2 of 2 parts: Crimes of Commission: Tax Perjury, Aiding Another and Hiding Assets
Listen Knowingly filing a false tax return and aiding another to do so are violations of the IRC, Section 7206. Briefly summarized, those violations encompass: Tax perjury — knowingly signing a false tax return that is false Willfully aiding another person to commit tax fraud Hiding assets with the intent to evade or defeat the …
Lowering the Bar for Willfulness for FBAR Penalties
Listen The IRS has authority to assert FBAR civil penalties.  Before delving into the FBAR abyss, this is a good time to debunk some FBAR myths.  First, there is no such thing as an FBAR penalty within the Offshore Voluntary Disclosure Program (OVDP).  The FBAR penalty exists only outside of the OVDP framework.  However, there …