Archives: Offshore

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Treasury and Other Agencies Issue Guidance to Banks on Correspondent Accounts

On Aug. 30, 2016, the Treasury Department, the Federal Reserve, the FDIC, the National Credit Union Administration and the Office of the Comptroller of the Currency issued guidance to U.S. banks that hold correspondent accounts for foreign financial institutions. The Joint Fact Sheet on Foreign Correspondent Banking seeks to clarify U.S. banks’ obligations when hosting … Continue Reading

Bank Leumi Enters Into DPA with U.S. Department of Justice

On December 22, 2014, the Department of Justice announced its agreement with Bank Leumi:  Bank Leumi Admits to Assisting U.S. Taxpayers in Hiding Assets in Offshore Bank Accounts  A major Israeli international bank admitted that it conspired to aid and assist U.S. taxpayers to prepare and present false tax returns to the Internal Revenue Service … Continue Reading

American Pleads Guilty to Hiding Money in Swiss Bank, Moving Money to Israeli Bank after UBS Scandal

On August 19, 2014, Bernard Kramer pleaded guilty in the Southern District of New York to conspiracy to defraud the United States and filing a false income tax return relating to his concealment of “at least $1.1 million” in bank accounts in Switzerland and Israel. The criminal information did not identify the banks.  For 23 … Continue Reading

Swiss Financial Institution Pays $4.4 Million and Turns Over 110 Americans

Bloomberg BNA reported on May 9, 2014, that Swisspartners Group resolved a U.S. criminal tax probe by forfeiting $3.5 million and paying $900,000 in restitution for helping U.S. clients evade taxes with secret accounts.  The bank also produced about 110 U.S. taxpayer client files to the U.S. authorities.  The agreement covers four Swisspartners entities: Swisspartners Investment Network AG, Swisspartners Wealth … Continue Reading

Hong Kong Agrees in Substance to FATCA IGA

On May 9, 2014, the U.S. Treasury announced that Hong Kong had agreed in substance on a Model 2 FATCA IGA.  Under the  IGA, Hong Kong financial institutions will report information on financial accounts held by U.S. persons directly to the Internal Revenue Service.  Hong Kong is only the seventh country to have chosen a Model … Continue Reading

Singapore Agrees in Substance to FATCA IGA

On May 6, 2014, the Ministry of Finance of Singapore announced that Singapore had agreed in substance on a Model 1 FATCA IGA.  Under the  IGA, Singapore-based financial institutions will report information on financial accounts held by U.S. persons to the Inland Revenue Authority of Singapore (IRAS), which will in turn provide the information to … Continue Reading

Israel Inks Model 1 FATCA IGA

Bloomberg BNA is reporting that Israel has signed a FATCA IGA.  The agreement is a Model 1 agreement, meaning that Israeli financial institutions will will report information about U.S. customers’ accounts to the Israeli  tax authorities, who will then send that information to the IRS. The news comes only a day after the indictment of … Continue Reading

Ex-Israeli Banker Indicted for Assisting Americans in Tax Fraud

On April 30, 2014, a federal grand jury in Los Angeles, California, indicted Shokrollah Baravarian for Klein conspiracy: conspiracy to defraud the United States by impairing and impeding the IRS. According to the indictment, Baravarian, a former senior vice president at the Los Angeles branch of a bank headquartered in Tel Aviv, Israel, widely believed … Continue Reading

Fugitive Swiss Banker Returns to U.S. and Enters Guilty Plea

On April 30, 2014, Josef Dorig, 72, of Switzerland, pleaded guilty in federal district court in Alexandria, Virginia, to a single count of Klein conspiracy: conspiracy to defraud the U.S. by impairing and impeding the IRS.  According to the agreed statement of facts that accompanied the plea agreement, Dorig owned a trust company and helped … Continue Reading

India Agrees “In Substance” to Model 1 FATCA IGA

The U.S. Treasury announced that on April 11, 2014, India agreed “in substance” to sign a Model 1 FATCA IGA with the US. The IGA would therefore require Indian financial institutions to report information on U.S. account holders to India’s Central Board of Direct Taxes, which would then share the information with the IRS.  There is … Continue Reading

U.S. Signs FATCA IGA with Luxembourg

On March 28, 2014, the U.S. signed a FATCA IGA with Luxembourg.  Under the IGA, banks and other financial institutions in Luxembourg will report information about eligible U.S. customers’ offshore accounts to the Luxembourg tax authorities, who will then send that information to the IRS. The IGA is reciprocal, requiring the IRS to send Luxembourg … Continue Reading

Levin and McCain Urge DOJ to Seek Extradition of Fugitive Swiss Bankers

Bloomberg news reports that on March 18, 2014, U.S. Senators Carl Levin and John McCain wrote a letter urging the Justice Department to seek extradition of about 30 Swiss bankers and others who are charged with enabling offshore tax evasion and failed to appear in federal courts. McCain and Levin, who lead the Senate Permanent … Continue Reading

IRS Report Announces Major Increase in Criminal Investigations for 2013

On February 24, 2014, IRS Criminal Investigation (“CI”) announced the release of its 2013 annual report, which reflected a significant increase in criminal investigations and prosecution recommendations in the past year.  According to the report, there was an increase of 12.5 percent in completed investigations and an increase of nearly 18 percent in prosecution recommendations … Continue Reading

Swiss Investment Adviser to Plead Guilty to Helping Americans Evade Taxes

Multiple outlets are reporting that on February 26, 2014, Martin Lack, a Swiss investment adviser and former UBS banker, will plead guilty in the Southern District of Florida to one count of conspiracy to defraud the United States by helping his U.S. customers evade their income taxes.  This comes on the heels of the February … Continue Reading

U.S. Signs Four More FATCA IGA’s

On February 5, 2014, the Treasury Department announced that it had recently concluded FATCA IGA’s with Canada, Hungary, Italy, and Mauritius.  All four agreements were reciprocal Model 1 agreements.  In other words, FFI’s in those countries will report information on U.S. account holders to their own governments for transfer to the IRS.  The IRS will … Continue Reading

Beanie Babies Creator Seeks Probation for $107 Million UBS Account

The Chicago Tribune reports that Beanie Babies creator Ty Warner, who pleaded guilty last year to one of the largest tax frauds in Chicago-area history, has asked the federal court to sentence him to probation. His sentencing is scheduled for January 14, 2014.  In 1996, Warner opened a Swiss bank account at UBS, which held … Continue Reading

Cayman Islands and U.S. Sign FATCA IGA

On November 29, 2013, the Cayman Islands and the U.S. Signed a FATCA IGA.  The Cayman Islands IGA is a Model 1B agreement, meaning that FFIs in the Cayman Islands will be required to report tax information about U.S. account holders directly to the Cayman Islands Tax Information Authority.  The Cayman Islands Tax Information Authority … Continue Reading

U.S. Signs FATCA IGA With France

Bloomberg BNA reports that the Treasury Department announced on November 14, 2013, that the U.S. and France have signed a Model 1 FATCA IGA.  In other words, the IGA will require banks in France to report tax information about U.S. account holders to the French government instead of to the IRS.  The French government will … Continue Reading

Voluntary Disclosures Lead to John Doe Summonses for Information about U.S. Accounts at Zurcher Kantonalbank and Bank of Butterfield

In a sign that the U.S. government continues to aggressively seek information on U.S. taxpayers with non-U.S. bank accounts, the government announced on November 12, 2013, that it had obtained a court order authorizing the government to issue so-called “John Doe summonses” for information on U.S. account holders at Zurcher Kantonalbank in Switzerland and Bank … Continue Reading

IRS Official Announces Crackdown on U.S. Taxpayers with Unreported Indian Accounts

Tax Analysts Tax Notes reports that the IRS Small Business/Self-Employed Division’s special enforcement program (SEP) will soon begin examining U.S. taxpayers suspected of holding undeclared accounts in Indian banks.  An IRS official announced on November 9, 2013, that the SEP team is preparing for the next phase of the IRS’s offshore compliance crackdown.  After receiving … Continue Reading
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