Phone: (310) 550-6200
Holtz, Slavett & Drabkin, APLC
  • Home
  • Tax Services
    • Foreign Bank Accounts and Offshore Tax Compliance
    • Tax Litigation
    • Tax Audit Representation
    • IRS Employee Retention Credit Audits
    • Tax Fraud and Tax Crimes
    • Tax Collection Defense
      • Offer in Compromise
      • Tax Levies
      • Tax Liens
      • Bankruptcy & Taxes
      • Innocent Spouse Relief
      • Trust Fund Recovery Penalties
    • Employment Taxes
    • Unfiled Tax Returns
    • Other Tax Services
  • Tax Attorneys
    • Gary M. Slavett
    • David C. Holtz
    • Igor S. Drabkin
    • David J. Warner
    • Michele F.L. Weiss
    • Scott Burkholder
    • Emma Warner
    • Kevin Oveisi
    • Richard Gano
  • Blog and News
    • Firm News
    • Internal Revenue Service
      • Audit
      • Criminal Tax
      • Employment Tax
      • Exempt Organizations
      • FBAR
      • Innocent Spouse Relief
      • Offshore Income
      • Trust Fund Recovery Penalty
    • California Employment Development Department
    • Franchise Tax Board
    • Sales Tax
    • Whistleblower Award
  • Contact
    • Los Angeles Office
    • Orange County Office
Select Page

IRS Rescinds Amnesty Approval for Bank Leumi Clients

by Igor Drabkin | Mar 7, 2013 | Criminal Tax, FBAR, Internal Revenue Service, Offshore Income

Israeli banknotes

This week, many tax attorneys who work with Offshore Voluntary Disclosure cases were surprised by the change of position by the IRS with respect to some taxpayers with accounts at Bank Leumi in Israel.  We and other tax practitioners received faxes from the Internal Revenue Service, informing us that some clients who were previously accepted into the IRS amnesty program for undisclosed offshore accounts, have “upon further review” been disqualified.  The faxes, signed by John R. Tafur, director of of Global Financial Crimes at the IRS’ Criminal Investigation division, affect dozens of American taxpayers who had undisclosed accounts at Bank Leumi, Israel’s  largest bank.

The change of position appears to affect clients with the so called “back-to-back” loans, when account holders obtained loans secured by the secret bank accounts, and the borrowed funds were used in the United States without disclosing the source.  This fact situation is similar to the recently announced plea deal in United States v. Sperling.

In a plea deal with prosecutors, Zvi Sperling, an Israeli-born Los Angeles businessman, admitted to hiding $4 million in unreported corporate profits in an account at Israeli “Bank A”–an account he opened around 2001 and owned through a front Island of Nevis corporation. According to the statement of facts in his plea deal, he then tapped into that money through loans from Bank A’s Los Angeles office.

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

Categories

Recent Posts

  • Michele Weiss Selected for Lawdragon 500 Leading Tax Lawyers Guide
  • IRS Cracking Down on Section 1202 Qualified Small Business Stock (QSBS) Claims
  • Six Holtz, Slavett & Drabkin Attorneys Named in 2025 Southern California Super Lawyers List
  • Michele Weiss to Present on Passthroughs Hot Topics at the Upcoming ABA Mid-Year Conference
  • IRS Issues Notice Providing Relief to California Wildfire Victims
Internal Revenue Service > Criminal Tax > IRS Rescinds Amnesty Approval for Bank Leumi Clients

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

Follow Us

LinkedIn

Recent Blog Posts

  • Michele Weiss Selected for Lawdragon 500 Leading Tax Lawyers Guide
  • IRS Cracking Down on Section 1202 Qualified Small Business Stock (QSBS) Claims
  • Six Holtz, Slavett & Drabkin Attorneys Named in 2025 Southern California Super Lawyers List
  • Michele Weiss to Present on Passthroughs Hot Topics at the Upcoming ABA Mid-Year Conference
  • IRS Issues Notice Providing Relief to California Wildfire Victims
  • IRS is Allowed to Serve John Doe Summons on a “Gig Economy” Platform
  • Holtz, Slavett & Drabkin to Sponsor 2024 Criminal Tax Fraud and Tax Controversy Conference in Las Vegas

    Designed by Elegant Themes | Powered by WordPress