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Taxpayers Can Still Make Voluntary Disclosures for Offshore Accounts

Taxpayers Can Still Make Voluntary Disclosures for Offshore Accounts

by Igor Drabkin | Dec 2, 2018 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income

On November 20, 2018, the IRS issued a Memorandum, describing the process for all voluntary disclosures following the closing of the 2014 OVDP on September 28, 2018. The new procedures are effective for all disclosures after September 28, 2018. Under the new procedures, the taxpayers with hidden foreign bank accounts, whose behavior may be considered willful, will find stricter requirements and higher penalties.

Think the Criminal Statute of Limitations for Failure to Report Foreign Bank Accounts Has Expired? Think Again.

Think the Criminal Statute of Limitations for Failure to Report Foreign Bank Accounts Has Expired? Think Again.

by David J. Warner | Nov 13, 2018 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income

In general, the United States has five years to start criminal proceedings in a criminal case (either through an indictment or information). 18 U.S.C. § 3282. However, there are several statutes that could suspend or extend this five-year period, and an individual might not even know if the statute of limitations has been extended.

Tax Crime Does Not Pay — Says Department of Justice

Tax Crime Does Not Pay — Says Department of Justice

by Igor Drabkin | Apr 11, 2018 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income

Tax Crime Does Not Pay — Says Department of Justice

IRS Offshore Voluntary Disclosure Program to End Soon

IRS Offshore Voluntary Disclosure Program to End Soon

by Igor Drabkin | Mar 13, 2018 | FBAR, Internal Revenue Service, Offshore Income

IRS Offshore Voluntary Disclosure Program to End Soon

Tax Court Rules for Taxpayer on Statute of Limitations Issue Related to Foreign Assets Reporting

Tax Court Rules for Taxpayer on Statute of Limitations Issue Related to Foreign Assets Reporting

by Igor Drabkin | Jan 8, 2018 | FBAR, Internal Revenue Service, Offshore Income, Tax Litigation

In Rafizadeh v. Commissioner, 150 T.C. No. 1, the Tax Court issued an important decision for the taxpayers, holding that the six-year statute of limitations with respect to income attributable to certain “specified foreign financial assets”, is effective only for those tax years to which the reporting requirement was applicable and in effect.

Southern California Residents Sentenced to Prison for Hiding Millions of Dollars in Secret Foreign Bank Accounts

Southern California Residents Sentenced to Prison for Hiding Millions of Dollars in Secret Foreign Bank Accounts

by Igor Drabkin | Apr 25, 2017 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income

Three Orange County, California residents were sentenced to prison today for willfully failing to file Foreign Bank Account Reports (FBAR), disclosing their secret accounts in Switzerland and Israel.

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Holtz, Slavett & Drabkin
Former IRS Tax Attorneys
(310) 550-6200
10940 Wilshire Boulevard
Suite 2000
Los Angeles, CA 90024

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  • IRS Enforcement Focuses on High Income Taxpayers, Puerto Rico Scheme and Malta Pension Arrangements
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Internal Revenue Service > Offshore Income

Los Angeles Main Office

10940 Wilshire Boulevard
Suite 2000
Los Angeles, CA 90024
Phone: (310) 550-6200
Fax: (310) 774-3904

Orange County Office

4695 MacArthur Court
Suite 200
Newport Beach, CA 92660
Phone: (949) 999-6606
Fax: (949) 544-0440

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Recent Blog Posts

  • Michele Weiss Interviews IRS National Taxpayer Advocate
  • Former IRS Attorney Kevin Oveisi Joins Holtz, Slavett & Drabkin
  • IRS Enforcement Focuses on High Income Taxpayers, Puerto Rico Scheme and Malta Pension Arrangements
  • Michele Weiss Quoted in Bloomberg Tax Article on FTB Conservation Easement Settlement Program
  • Michele Weiss Quoted in Tax Notes Today Article About ERC Fraud
  • Michele Weiss Speaking at the ABA Tax Section May 2023 Meeting
  • David J. Warner and Michele Weiss Analyze Strategies for IRS Audits of the Employee Retention Credit for Strafford Webinar

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