The IRS’s Position Regarding Disclosures Made Outside a Targeted Voluntary Disclosure Program

Other Posts in this Series A History of the IRS’s Targeted Offshore Voluntary Disclosure Programs Pursing a Claim for the Refund of a Penalty Paid Through an Offshore Voluntary Disclosure Program Part Four: Examining the Limitations a Closing Agreement Places on Tax Litigation OVDP Penalty Refund - Setting Aside the...

Tax Case of the Week: Trust Fund Recovery Penalty for a Responsible Person

This week, the Court of Appeals for the 4th Circuit decided a case regarding whether the trust fund recovery penalties were properly imposed against an individual, who was an officer of the corporation that failed to pay over payroll tax, but was not involved with day to day operations, and...

DOJ: Hiding assets in Switzerland is ‘beyond foolish’

U.S. citizens and permanent residents are required by law to report any assets held in foreign bank accounts to the Internal Revenue Service (IRS). With the upcoming implementation of the Foreign Account Tax Compliance Act (FATCA), it will be extremely difficult for Americans to conceal funds held in other countries....

Offshore Initiative – Another NPA reached: DOJ 23.8 million settlement with Liechtensteinische Landesbank AG (LLB-Vaduz)

On July 29, the United States Justice Department (DOJ) announced in a press release that it had reached a $23.8 million settlement with Liechtensteinische Landesbank AG (LLB-Vaduz), halting its criminal investigation of the bank in aiding US citizen's in evading their U.S. tax obligations.   As part of the investigation, the...

Santa Clara County man pleads guilty to hiding Israeli bank account

On July 17, the U.S. Justice Department announced in a press release that Moshe Handelsman of Saratoga, California, plead guilty to tax perjury. This case is the latest in a series involving un-reported foreign bank accounts and Israeli banks under scrutiny by the Justice Department and Internal Revenue Service (IRS)...