http://www.taxproblemattorneyblog.com/ Published by Brager Tax Law Group en-us 2010-07-16T13:45:55-08:00 http://www.taxproblemattorneyblog.com/2010/07/credit_suisse_next_on_the_fbar.html Credit Suisse’s offices in Germany were raided by German tax officials looking for evidence of tax fraud. According to an article by Judy Dempsey in the New York Times all 13 German branches of Swiss bank Credit Suisse were searched,... Offshore Bank Account Problems Dennis N. Brager 2010-07-16T13:45:55-08:00 http://www.taxproblemattorneyblog.com/2010/07/irs_fbar_net_noose_tightens_to_1.html In February I noted that two clients with offshore bank accounts at HSBC had been indicted for FBAR (Foreign Bank Account Report) violations and related tax evasion charges. Last week Clare Baldwin reported through Reuters news service that some tax... Offshore Bank Account Problems Dennis N. Brager 2010-07-12T18:08:53-08:00 http://www.taxproblemattorneyblog.com/2010/07/age_is_no_bar_to_offshore_bank_1.html Failure to file a Foreign Bank Account Report (FBAR) on TDF 90-22.1 is crime under the Bank Secrecy Act punishable by up to 5 years in jail. Failure to file an FBAR usually goes hand in hand with tax fraud,... Offshore Bank Account Problems Dennis N. Brager 2010-07-01T15:13:50-08:00 http://www.taxproblemattorneyblog.com/2010/06/fbar_confusion_reigns_financia_1.html Foreign Bank Account Reports (FBAR) on Form TDF 90-22.1 are due in Detroit, Michigan on June 30th. Some CPAs and tax attorneys seem to be relying on an exception contained in IRS Notice 2010-23 which provides that persons who have... Offshore Bank Account Problems Dennis N. Brager 2010-06-25T09:55:05-08:00 http://www.taxproblemattorneyblog.com/2010/06/ubs_offshore_swiss_account_vol.html The Swiss Parliament has decided to allow UBS to turn over the names of its Swiss bank account customers to the IRS. This means that the names of 4,450 UBS customers who are suspected of committing tax fraud, and FBAR... Offshore Bank Account Problems Dennis N. Brager 2010-06-18T16:10:57-08:00 http://www.taxproblemattorneyblog.com/2010/06/ubs_offshore_tax_fraud_case_ta.html UBS Swiss Bank account owners who did not make a voluntary disclosure to the IRS last year breathed a sigh of relief when the lower house of the Swiss Parliament voted against amending the U.S. Swiss Tax Treaty to allow... Offshore Bank Account Problems Dennis N. Brager 2010-06-09T10:29:21-08:00 http://www.taxproblemattorneyblog.com/2010/05/irs_says_it_will_subpoena_cpas_1.html A couple of weeks ago I was at the ABA Tax Section Meeting which as I mentioned previously gathered tax lawyers from around the country. Since I spent most of my time at meetings involving FBARs (Foreign Bank Account Report... Offshore Bank Account Problems Dennis N. Brager 2010-05-21T10:59:53-08:00 http://www.taxproblemattorneyblog.com/2010/05/offshore_bank_account_problems.html According to Kevin Downing, a senior tax attorney of the U.S. Department of Justice, the U.S. government expects over the next couple of years to bring somewhere between 4,000 and 7,000 more cases against wealthy individuals committing tax fraud through... Offshore Bank Account Problems Dennis N. Brager 2010-05-13T15:58:35-08:00 http://www.taxproblemattorneyblog.com/2010/05/fbars_and_more_fbars_1.html I just returned from an ABA meeting of tax lawyers in Washington, D.C. It seemed like all of the tax attorneys (or at least the tax litigation attorneys) could find nothing to talk about, but Foreign Bank Account Reports, i.e.... Offshore Bank Account Problems Dennis N. Brager 2010-05-11T13:10:23-08:00 http://www.taxproblemattorneyblog.com/2010/05/ubs_fbar_indictment_illustrate_1.html Disbarred New York attorney Kenneth Heller was among 7 UBS clients charged a few weeks ago with failing to file Foreign Bank Account Reports, TDF 90.22-1 (FBARs), and tax evasion as a result of failing to report his Swiss bank... Offshore Bank Account Problems Dennis N. Brager 2010-05-03T09:56:59-08:00