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IRS & DOJ Announcements - Voluntary Disclosure Consultation 305-576-4242

July 6, 2017 - IRS Country-by-Country Reporting
The United States is a member of the Organization for Economic Co-operation and Development (OECD). The OECD recommended country-by-country reporting requirements to address base erosion and profit shifting. The United States issued regulations to require country-by-country reporting by U.S. multinational enterprises (MNEs).

April 25, 2017 - Lois Lerner, Former IRS Official, Remains Relevant On Tax Day
On April 9, 2014, the House Committee on Ways and Means voted to send a letter to the Department of Justice referring former IRS Exempt Organizations Division Director Lois G. Lerner for criminal prosecution. As indicated in the attached letter, the Committee’s nearly three-year investigation uncovered evidence of willful misconduct on the part of Ms. Lerner. Despite this fact, and for what many believe were purely partisan reasons, the prior Administration refused to review Ms. Lerner’s misconduct.”

March 29, 2017 - IRS Targeting Report

March 29, 2017 - IRS still allowed to target political groups, according to watchdog org
A rule in place at the IRS allows the federal agency to delay the applications of non-profit groups looking for tax-exempt status, claims the Washington-based Cause of Action in its report, “A Hidden Cause of the IRS Targeting Scandal.”

March 24, 2017 - Florida Businessman Pleads Guilty To Conspiracy To Commit Tax And Bank Fraud
Padula created two offshore companies in Belize: Intellectual Property Partners Inc. (IPPI) and Latin American Labor Outsourcing Inc. (LALO). He opened and controlled bank accounts in the names of these entities at Heritage International Bank & Trust Limited (Heritage Bank), a financial institution located in Belize. From 2012 through 2013, Padula caused periodic payments to be sent from Demandblox to his accounts at Heritage Bank and deposited approximately $2,490,688.

January 18, 2017 - Southern California Residents Plead Guilty to Hiding Millions of Dollars in Secret Foreign Bank Accounts
In August 2008, Azarian, also opened an undeclared account at Israeli Bank A in Israel, and in May 2009, he closed his undeclared account held at Credit Suisse and transferred the funds to Israeli Bank A. Azarian later partially declared this Israeli Bank A account on his individual income tax returns. At the time of its closure, Azarian’s undeclared account at Credit Suisse held assets valued at approximately $1,903,214.

December 20, 2016 - COURT AUTHORIZES SERVICE OF JOHN DOE SUMMONS SEEKING THE IDENTITIES OF U.S. TAXPAYERS WHO HAVE USED VIRTUAL CURRENCY
A federal court in the Northern District of California entered an order today authorizing the Internal Revenue Service (IRS) to serve a John D oe summons on Coinbase Inc., seeking information about U.S. taxpayers who conducted transactions in a convertible virtual currency during the years 2013 to 2015.

December 1, 2016 - Court Authorizes Service of John Doe Summons Seeking the Identities of U.S. Taxpayers Who Have Used Virtual Currency
A federal court in the Northern District of California entered an order today authorizing the Internal Revenue Service (IRS) to serve a John Doe summons on Coinbase Inc., seeking information about U.S. taxpayers who conducted transactions in a convertible virtual currency during the years 2013 to 2015. The IRS is seeking the records of Americans who engaged in business with or through Coinbase, a virtual currency exchanger headquartered in San Francisco, California.

August 2, 2016 - California Businessman Charged with Conspiring with Israeli Banks to Hide Income
“Mr. Sarshar stashed millions in secret foreign financial accounts in Israel and then sought to use these accounts to evade his U.S. tax obligations, seeking to cover his tracks along the way,” said Principal Deputy Assistant Attorney General Ciraolo. “The message of this case is clear: There are no safe havens. If you are concealing assets and income in undeclared offshore accounts – or are a banker, an asset manager or otherwise are assisting accountholders in such criminal conduct, your only viable option is to come forward and accept responsibility for your actions. Those who continue to violate U.S. tax laws will be held accountable and pay a heavy price.”

May 12, 2016 - Notice of proposed rulemaking
Treatment of Certain Domestic Entities Disregarded as Separate From Their Owners as Corporations for Purposes of Section 6038A

Janaury 7, 2016 - Justice Department Announces Resolution under Swiss Bank Program with Union Bancaire Privée, UBP SA
The Department of Justice announced today that Union Bancaire Privée, UBP SA (UBP), reached a resolution under the department’s Swiss Bank Program. UBP will pay a penalty of more than $187 million.

December 15, 2015 - Three Banks Reach Resolutions Under Swiss Bank Program
The Department of Justice announced today that Crédit Agricole (Suisse) SA (CAS), Dreyfus Sons & Co Ltd, Banquiers (Dreyfus), and Baumann & Cie, Banquiers (Baumann), reached resolutions under the department’s Swiss Bank Program. These banks collectively will pay penalties of more than $130 million.

December 9, 2015 - FATCA – FAQs General
Updated FAQs for FATCA.

November 19, 2015 - Justice Department Announces Three Banks Reach Resolutions Under Swiss Bank Program
The Department of Justice announced today that BNP Paribas (Suisse) SA (BNPP), KBL (Switzerland) Ltd. (KBL Switzerland) and Bank CIC have reached resolutions under the department’s Swiss Bank Program. T

October 19, 2015 - Justice Department Announces BBVA Suiza S.A. Reaches Resolution under Swiss Bank Program
Since Aug. 1, 2008, BBVA Suiza maintained 138 U.S.-related accounts with a maximum aggregate dollar value of more than $157 million. BBVA Suiza will pay a penalty of $10.390 million.

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