Offshore Bank Expert Attorney Anthony Parent Creates New Video about the June 2013 FBAR Update

The Helpful Video, which is Posted on YouTube, Explains What the Latest FBAR Update Means for Taxpayers

Anthony Parent, the founder of IRS Medic at Parent and Parent, a firm of tax attorneys who are devoted to helping their clients with tax-related issues, has just created a new video titled “June 2013 FBAR Update.” The in-depth video, which the FBAR attorney has posted on YouTube, explains in great detail what the latest FBAR update means for taxpayers.

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5 things you must know about FBAR penalty negotiations

 As you probably know, the IRS has a new focus on FBAR penalty enforcement. Because of the strange history of the form and the Bank Secrecy Act, many people can’t quite figure out what what all of this means. In order to help you understand the most essential facts, here is list of 5 things you must absolutely know about FBAR Penalty negotiations.

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IRS Crackdown on Quiet/Soft Disclosures, promising audits and big penalties

Tens of thousands of taxpayers, and tax professionals decided to ignore warnings by the IRS and created a reporting scheme often called soft or quiet disclosure, something done by amending his past tax returns and filing delinquent tax FBARs without participating in the Offshore Voluntary Disclosure Program (OVDP). These crafty taxpayers looked at the FBAR-equivalent penalties (5-27.5%o f highest account value)  and thought they were too high and ignored IRS warnings. They hoped when they put all their foreign account information on an IRS form, they could cross their fingers and the IRS might leave them alone.

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June 2013 IRS FBAR News & Updates

With all the FBAR news coming out, I thought it would be a good idea to do a quick video to go over some of the bigger FBAR?OVDP news developments.

In this two-part video series, I :

(1) give a quick overview the FBAR form and its filing requirements
(2) describe the IRS crackdown on so-called soft or quiet disclosures
(3) report on news that the IRS has made no efforts to educate expatriate or recent immigrants, dual citizen, resident aliens, and VISA holders,
(4) mention FBAR education resources for tax payers, tax professionals and estate planning attorneys, and
(5) explain why many CPAs and attorneys have stopped dabbling in OVDI cases, and (6)  advise those who filed under the 2009 that they have a limited amount of time to claim a penalty reduction.

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Here is a letter form Jackie Bugnion, director of American Citizens Abroad:

To the Editor:

In his article, “The IRS Is in Big Trouble,” Tax Notes (no link, paywall), May 20, 2013, p. 951 , Christopher Bergin stated that the scandal surrounding the treatment of Tea Party applicants for section 501(c)(4) status may be the canary in the coal mine. I would like to highlight one other scandal which was signaled by National Taxpayer Advocate Nina Olson, but was ignored by former IRS Commissioner Douglas Shulman — the “bait and switch” tactics of the IRS under the overseas voluntary disclosure program (OVDP).

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Another whistleblower gives IRS information on potential tax evasion

Switzerland’s bank secrecy laws have protected clients’ names and accounts for years, in effect allowing such clients to squirrel their finances away to avoid their own country’s tax laws. In 2009 the UBS case shed light on how one of Switzerland’s premier banks would knowingly assist its clients in schemes to avoid taxes. Even after the resolution of the UBS case the Swiss banking regime steadfastly retained its bank secrecy laws; laws which, when broken, carried potentially serious consequences for the breaching party. Most recently the Swiss government requested that Spain extradite one Herve Falciani, to face trial in Spain for his breach of bank secrecy laws, but Spain refused to grant the request because the Spanish court considered Switzerland’s secrecy laws, at least in Falciani’s circumstances, to run contrary to important EU public policy considerations.

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Offshore Voluntary Disclosure Program (OVDP) Accountability Update

By: AMY L. HOLBROOK, Esq

The United States Government Accountability Office (GAO, an independent entity that exists to audit, evaluate, and investigate federal government activities to support Congress) has just released a report to Congress on offshore tax evasion and its findings regarding the 2009 program data and results.The full report can be found here:  http://www.gao.gov/assets/660/653369.pdf  and has some fascinating metrics and data collation regarding the first OVDP from 2009. 

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What to do if you are one of the 24,000 HSBC bank account holders who has not disclosed foreign accounts

In unsettling news for US persons who have not disclosed the existence of foreign accounts to the IRS, Herve Falciani, an IT worker at HSBC’s Geneva branch, stole the names of 24,000 HSBC customers with private accounts and in 2008 he gave that data to Christine Lagarde, the former Finance Minister of France, and current head of the International Monetary Fund. Lagarde shared that list – often referred to as the “Lagarde List” – with the IRS and several EU authorities. As a result of the revelation, many HSBC account holders now face the threat of prosecution for tax evasion by the IRS and have a limited amount of time to come clean or risk detection.

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“I returned, and saw under the sun, that the race is not to the swift, nor the battle to the strong, neither yet bread to the wise, nor yet riches to men of understanding, nor yet favour to men of skill; but time and chance happeneth to them all.”

Ecclesiastes 9:11 King James Bible (Cambridge Ed.)

FBAR Amnesty for those who did nothing wrong

I thought of my good friend Ecclesiastes today, while reading a New York Times article, “Many Americans Abroad Surprised by Tax Code’s Nasty Bite.” I recalled my feeling that the above passage was incomplete. If my years in tax and criminal law have taught me anything, I would add just one more exclusionary caution: “nor punishment to the guiltiest.”

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Department of Justice continues to hammer those with unreported foreign bank accounts

California pair gets the IRS FBAR hammer

The FBAR penalty the IRS seeks to assess on taxpayers failing to report their foreign accounts is wildly out of proportion with the crime committed. We’ve discussed previous instances of horrifically massive FBAR penalties the IRS has squeezed non-compliant taxpayers into accepting.

With a recent case from Los Angeles, the trend continues. Those with unreported accounts and unreported income who do not utilize the  Offshore Voluntary Disclosure Program (OVDP/OVDI) are treated more harshly than outright thieves, as a pair recent Israeli/Luxembourg FBAR cases from California demonstrates.

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