A New York City man pleaded guilty today to a criminal information charging him with tax evasion for tax years 2003 through 2005 and 2007 through 2010, announced Principal Deputy Assistant Attorney General Caroline D. Ciraolo, head of the Justice Department’s Tax Division, and U.S. Attorney Robert L. Capers of the Eastern District of New York.

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This is a continuation of Part I. This hypothetical pertains to a taxpayer who has applied to OVDP and who has transferred assets from one foreign account, which was recently closed, to another during the disclosure period.

This is a simple example, yet it illustrates some of the common mistakes that are associated with double counting.

Joe has applied to the OVDP. He had two foreign accounts in 2010: one at Bank A and another at Bank B.

The opening balances in each account were as follows: Read More

When looking for a picture for this post, I came across this one and remembered my college English Professor. She really loved the term, “Freudian Slip” for some reason! All I knew then was that Sigmund Freud was the father of psychoanalysis but I never quite understood how that related to a Business English class, unless that was the Professor’s way of telling us we were driving her nuts! Now I know that the term, “Freudian Slip” is a “mistake in speech that shows what the speaker is truly thinking” or “to do what one is truly thinking about”.

No, this post is not about defining psychoanalytic terms, dare I say more interesting than tax stuff? Not quite, but this post is about the latest buzz from the Internal Revenue Service, about some situations US taxpayers having foreign accounts might be in and their Read More

It is not illegal to put your money in overseas bank accounts or to have foreign financial interests. It is, however, against U.S. law to hide it in order to avoid paying income taxes. In the past, the IRS was not very successful in going after all that untaxed wealth. According to a 2012 Forbes online piece, the “super rich” were hiding an astonishing $21 Trillion (with a T!) in foreign accounts.


In a previous blog, we highlighted how FATCA widened the net in uncovering all that wealth. FATCA is, among other things, the tool the IRS uses to find out about U.S. account holders and about those who abet anonymity by hiding the identity of their owners. Read More