IRS Releases New Guidance on Voluntary Tax Disclosures

Written by McNair Law Firm Dec. 3 2018 https://www.jdsupra.com/legalnews/irs-releases-new-guidance-on-voluntary-85195/ A bedrock of IRS administrative practice has been the voluntary disclosure. Where an individual or business has not filed tax returns or believes they may have criminal tax exposure for prior actions, IRS procedures have long-sanctioned a form of  “criminal tax amnesty” if the taxpayer Read More

NYT: U.S. Prosecutors Bring Their First Charges Over the Panama Papers

By Jesse Drucker Dec. 4, 2018 https://www.nytimes.com/2018/12/04/business/panama-papers-indictment.html Federal prosecutors in Manhattan unsealed an indictment on Tuesday that contained the first charges brought in the United States in connection with the so-called Panama Papers leak. The indictment, which a grand jury returned in late September, names four men connected to Mossack Fonseca, the Read More

Federal Tax Crimes

California Plastic Surgeon Sentenced to One Year and One Day for FBAR Violation (9/14/18) Posted: 24 Sep 2018 08:33 AM PDT DOJ announced here another sentence related to offshore accounts.  Marc Edward Mani, a prominent Beverly Hills plastic surgeon, was sentenced for one plea count of FBAR violation.  I previously reported his plea:  Another Plea Agreement for Offshore Account (7/29/17; 7/30/17), here.  I also Read More

5 Points To Consider As Overseas Disclosure Program Ends

By Amy Lee Rosen Law360, Los Angeles (May 14, 2018, 10:42 PM EDT) -- While the IRS’ termination of the Offshore Voluntary Disclosure Program has left many hopeful it will be extended or replaced, potential violators who have yet to disclose their foreign bank accounts need to weigh their options, with the most important question being whether to enter the program before it shuts down. The IRS decided in March it Read More

Cash deposits will be limited to account owners or authorized signers

What is happening To help reduce criminal activity and protect your account, we'll be making changes to our policy for cash deposits made at Wells Fargo branches. Once our policy takes effect in a few weeks, we'll only accept cash deposits into your Wells Fargo Consumer checking or savings accounts if it is coming from an account owner or authorized signer. What you should know If a non-account owner needs to deposit Read More

Look Out, Meghan Markle! The IRS Is Watching

Some timely advice before a royal wedding that will raise daunting and complex tax issues By Laura Saunders Dear Meghan, Congratulations on finding your Prince Charming! I don’t want to be the bad fairy at the festivities, but we need to have a serious talk about taxes. Meghan, I know you lived as a U.S. citizen in Canada and may be aware of tax issues faced by the seven million or so Americans living abroad. And I Read More

Ex-CFO Of 'Soup Nazi' Co. Gets 9 Months For Tax Evasion

By: Taylor Arluck  The former chief financial officer of the business popularized by the "Soup Nazi" character in the sitcom "Seinfeld" received a nine-month sentence on Thursday in New York federal court for failing to pay federal income, Medicare and Social Security taxes. Soupman Inc.'s former CFO Robert N. Bertrand, 63, received a nine-month prison sentence followed by a one-year term of supervised release after Read More

OVDP Ending – FAQs from the IRS

1.  Is the 2014 OVDP closing? Yes. The IRS will close the 2014 OVDP effective September 28, 2018. The FAQs for the 2014 OVDP provided that the program may close stating: “[T]he terms of this program could change at any time going forward. For example, the IRS may increase penalties or limit eligibility in the program for all or some taxpayers or defined classes of taxpayers – or decide to end the program entirely at Read More

IRS to end offshore voluntary disclosure program; Taxpayers with undisclosed foreign assets urged to come forward now

WASHINGTON – The Internal Revenue Service today announced it will begin to ramp down the 2014 Offshore Voluntary Disclosure Program (OVDP) and close the program on Sept. 28, 2018. By alerting taxpayers now, the IRS intends that any U.S. taxpayers with undisclosed foreign financial assets have time to use the OVDP before the program closes. “Taxpayers have had several years to come into compliance with U.S. tax laws Read More

IRS instructs its auditors on IRC 6038A summons issuance and taxpayer noncompliance

From ThomsonReuters In an International Practice Unit (IPU), IRS has set out for its auditors the steps they should take when issuing a summons under Code Sec. 6038A and the steps to take if the domestic corporation to which it issues the summons does not substantially comply with the summons. Code Sec. 6038A requires reporting by domestic corporations that are at least 25% foreign owned. Background. Subject to Read More