
Igor S. Drabkin, J.D., Former IRS Attorney
Another client of UBS AG, one of the Swiss banking giants, has pleaded guilty to filing a federal income tax return. According to the U.S. Department of Justice, Roberto Cittadini of Bellevue, WA, accepted responsibility for concealing nearly $2 million in Swiss bank accounts. Cittadini failed to report income from bank accounts under his control at UBS in Switzerland on his individual income tax returns from 2001 through 2003. He also failed to file a Report of Foreign Bank and Financial Accounts (FBAR) for each of those years. He faces a maximum sentence of three years incarceration and a maximum fine of $250,000, DOJ said, adding that Cittadini agreed to pay a civil FBAR penalty based on 50% of the highest account balance from 2001 to 2007. Cittadini’s guilty plea follows recent guilty pleas in UBS-related cases by individuals in California, Florida, New Jersey and New York. “Individuals all over the country who are hiding income and assets in offshore accounts would be well-advised to promptly come in and come clean before the government learns about their accounts through other channels,” said John DiCicco, acting assistant attorney general of the Justice Department’s Tax Division. “IRS continues its pursuit of those hiding their income and assets in offshore accounts,” said Eileen Mayer, Chief of IRS’s Criminal Investigation. “We encourage people who have been hiding money offshore to come forward by Oct. 15 to take advantage of the special provisions in our voluntary disclosure effort.”
We remind everyone that the deadline for voluntary disclosing foreign financial accounts to the IRS expires on October 15, 2009. On September 21, the IRS extended the deadline to October 15th, but specifically stated that this deadline will not be extended.
If you have questions about the Offshore Voluntary Disclosure program or FBARs, please contact Former IRS Attorneys of Holtz, Slavett & Drabkin at (310) 550-6200.
Author: Igor S. Drabkin, J.D., Former IRS Attorney.
Copyright (c) 2009 Igor S. Drabkin. All Rights Reserved.