Daugerdas Sentenced to 15 years in Prison for Orchestrating Massive Fraudulent Tax Shelter Scheme
Paul M. Daugerdas, a 63 year-old tax attorney and certified public accountant, was sentenced on June 25, 2014 to serve 15 years in prison for orchestrating a massive fraudulent tax shelter scheme in which he and his co-conspirators designed, marketed, and implemented fraudulent tax shelters used by wealthy individuals to evade over $1.6 billion in […]
New Streamlined Filing Procedures: A Trap For the Unwary?
I recently attended the NYU’s Tax Controversy Forum. Two of the panelists were officials from the IRS: Jennifer Best, Senior Advisor, IRS Large Business and International Division, and John McDougal, special trial attorney and division counsel, IRS Small Business and Self-Employed Division. Both offered insight into the newly expanded streamlined filing procedures. One of the […]
Understanding the Streamlined Filing Compliance Procedures
On Wednesday, June 18, 2014, the IRS overhauled the Offshore Voluntary Disclosure Program while expanding and modifying the streamlined filing procedures in order to accommodate a broader group of U.S. taxpayers. Major changes to the streamlined procedures include the following: (1) extension of eligibility to U.S. taxpayers residing in the U.S., (2) elimination of the […]
Transitioning From 2012 OVDP to Streamlined Compliance Procedures: Q & A
(1) What is the purpose of transitional treatment under OVDP? Transitional treatment under OVDP allows taxpayers currently participating in OVDP who meet the eligibility requirements for the expanded Streamlined Filing Compliance Procedures announced on June 18, 2014, an opportunity to remain in the OVDP while taking advantage of the favorable penalty structure of the expanded […]
Offshore Account Penalties to Double With Start of 2014 OVDP Program
On Wednesday, June 18, 2014, the IRS announced that it was trying to make it easier for taxpayers to come clean about offshore accounts. The Service made changes to two key programs – one intended for taxpayers that willfully sought to evade tax laws, and another for those that avoided taxes despite trying to comply […]
The Dawn of a New Day For U.S. Citizens With Undisclosed Offshore Accounts
Hold on to your seats! The IRS just recently announced changes to its offshore voluntary compliance programs and it more than likely will affect you! The changes that were announced on June 18, 2014 are expected to help both taxpayers living abroad and those living within the United States come into compliance with their U.S. […]
Anatomy of a Criminal Tax Case: From Investigation to Prosecution
The traditional means of developing a criminal tax case is the so-called administrative route. This article describes administrative cases from four perspectives: (1) origin of the case; (2) investigation by CI; (3) moving the case from CI to DOJ; and (4) case processing by DOJ. I. Origin of the Case ** Traditionally, the largest source […]
FBAR Compliance Is Not Quite Painless, But It Beats the Alternative
It is not illegal to put your money in overseas bank accounts or to have foreign financial interests. It is, however, against U.S. law to hide it in order to avoid paying income taxes. In the past, the IRS was not very successful in going after all that untaxed wealth. According to a 2012 Forbes […]
FBAR Penalty Applies to Online Poker Accounts
Recently, a federal court case held that online poker accounts must be disclosed on an FBAR. In United States v. Hom, 2014 U.S. Dist. LEXIS 77489 (N.D. CA 2014), Mr. Hom was an online gambler who opened up accounts with two online poker websites in 2006: PokerStars and PartyPoker. Both websites allowed Mr. Hom to deposit and withdraw […]
Extra! Extra! Read All About It! IRS Commissioner Announces That Changes Are In the Offing For OVDP 2012
On June 3, 2014 the new IRS Commissioner, John A. Koskinen, gave a speech before the International Business – OECD International Tax Conference. His speech covered the history of the offshore enforcement initiative since the UBS debacle in 2009. His remarks acknowledge what most professionals in the tax community have recognized since the inception: that […]