Tax Crimes

No Laughing Matter: The Criminal Consequences of Failing to Report Foreign Bank Accounts
Listen United States citizens, residents and other persons must annually report their direct or indirect financial interest in, or signature authority over, a financial account that is maintained with a financial institution located in a foreign country if, for any calendar year, the aggregate value of all foreign accounts exceeded $ 10,000 at any time …
Add the Letter ‘T’ to FATCA, and No One’s Getting Fat Except the IRS
Listen In 2010 President Obama signed P.L. 111-147, the Hiring Incentives to Restore Employment Act. The purpose of the law is in its eponymous title, but the IRS got into the act with the Foreign Account Tax Compliance Act (FATCA) provisions. FATCA is an attempt by the IRS to “improve reporting compliance” — translation: “widen the …
IRS’s Treatment Of Elderly Cancer Researcher Sends Strong Message To Taxpayers That IRS Means Business When It Comes To Prosecuting Individuals For Tax Evasion
Listen A prominent cancer researcher has learned a valuable and humbling lesson: Do not try to outsmart the IRS. Peter Urrea was sentenced to 18 months in federal prison for cheating on his taxes. While most tax cheats avoid criminal prosecution and instead pay high civil penalties, Peter Urrea is an exception. What did he …
Rescued From the Brink of Insanity: Practical and Sound Advice for Making the Decision to Opt Out of the OVDI — Part II
Listen Hypotheticals Demonstrating When Opting Out is Detrimental To the Taxpayer Under what circumstances might opting out of the OVDI be detrimental for the taxpayer?  Below are two examples. Example 3: Large Unreported Gain Kevin is a U.S. citizen. In 2008, he opened a checking account in Country A with funds upon which U.S. taxes …
Rescued From the Brink of Insanity: Practical and Sound Advice for Making the Decision to Opt Out of the OVDI — Part I
Listen While reading can aid in learning, there is no substitute for doing.  Reading about what steps to take to solve a tax problem is no different than reading about how to ride a bicycle.  In the same way that the only way to learn how to ride a bicycle is by experiencing it firsthand – …
OVDI: Is the IRS Playing Fair?
Listen A Message From Uncle Sam to Taxpayers Who Have Undisclosed Foreign Bank Accounts: The Clock Is Ticking Since 2009, the IRS has offered taxpayers with undisclosed foreign financial accounts the opportunity to “come clean” under its Offshore Voluntary Disclosure Initiative (OVDI).  According to the IRS, more than 38,000 U.S. taxpayers have entered the program.  …