New Global Partnership Formed to Combat International Tax Crime

Law enforcement leaders from five countries have joined efforts in their fight against international tax crime and money laundering. The new “Joint Chiefs of Global Tax Enforcement” (J5) brings together tax enforcement authorities from Australia, Canada, the Netherlands, the U.K. and the U.S. to develop new strategies in the pursuit...

The Colliot Case, Part II: $100,000 Limit on Civil FBAR Penalties

In Part I, we discussed a very significant case involving a taxpayer who willfully failed to file FBARs for a number of years. Mr. Dominique Colliot objected to the extraordinary penalties assessed against him, arguing that 31 CFR 1010.820(g)(2) , the federal regulation used by the IRS to justify its...

Update on IRS Offshore Initiatives: Investigations and agreements with financial institutions worldwide

In our last post, we noted that the U.S. government goes to great lengths to identify and prosecute noncompliant taxpayers, as well as promoters and financial institutions who assist U.S. taxpayers avoid their tax obligations by hiding their offshore income and assets. Some recent plea agreements with large financial institutions...

Update on IRS Offshore Initiatives

Global tax issues are a top priority for the Internal Revenue Service Criminal Investigation Division (IRS-CI), which focuses its work on investigating taxpayers who willfully engage in tax evasion. Significant efforts are also being made to identify and take legal action against promoters and financial institutions who have assisted taxpayers...