FBAR Lawyers

A Senior Citizen With Offshore Accounts in Panama Pleads Guilty | IRS News

On May 26, 2017, the IRS scored another victory against Offshore Accounts in Panama and again against a senior citizen. This time, Ms. Joyce Meads, a 73-year old Texas resident, pleaded guilty to conspiring to defraud the United States by using offshore accounts in Panama to conceal more than $1.3 million in royalty income that she earned from oil wells.

Offshore Accounts in Panama: Facts of the Meads Case

According to documents and information provided to the court, from approximately April of 1997 through April of 2010, Ms. Meads conspired with offshore promoters to disguise more than $1.3 million in royalty income (from oil wells) as scholarships and loans from a foreign corporation that she set up.

In particular, Ms. Meads set up nominee companies in Delaware and Panama in the name of W.G. Holdings Corporation. Then, she transferred her interest in the oil wells to the nominee entity in Delaware, which resulted in all of the royalty checks to be issued to W.G. Holdings and sent to a Miami post office box. The checks were picked up there and sent by a courier to Panama to be deposited into Ms. Meads’ nominee accounts. Later, as it was mentioned above, the funds were repatriated as scholarships or loans from W.G. Holdings to herself. Ultimately, the funds ended up on her bank accounts and the accounts that were opened in her mother’s name.

During all of the relevant years, Ms. Meads never reported her income on her tax returns. Nor did she ever file an FBAR with respect to her offshore account in Panama. As part of the guilty plea, Ms. Meads admitted that she caused a tax laws of more than $250,000.

The IRS identified the promoters who helped Ms. Meads in her conspiracy to evade taxes. They are Marc Harris of The Harris Organization, Republic of Panama, and Boyce Griffin of Offshore Management Alliance Ltd., Republic of Panama. Both of them have already been convicted of conspiracy and other charges and were previously sentenced to prison.

Offshore Accounts in Panama: Potential Jail Time and FBAR Penalties

The sentencing of Ms. Meads is scheduled for August 4, 2017. Ms. Meads faces a statutory maximum sentence of five years in prison, a period of supervised release, restitution and monetary penalties. The penalties will likely include not only income tax fraud penalties, but also FBAR penalties.

Offshore Accounts in Panama: Lessons from the Meads Case

The Meads case is a classic example of a situation that leads to an IRS criminal investigation. Let’s focus on three main factors here.

First, Ms. Meads was diverting pre-tax US-source income from the United States to an offshore tax shelter. Based just on this fact, the IRS has sufficient incentive to make an example of her. In fact, diverting US-source income to a tax shelter might be the most important factor that led to criminal penalties in this case.

Second, Ms. Meads utilized a shell corporations to hide her income. Involving foreign companies in a tax evasion scheme is a very common factor that leads to an IRS criminal investigation.

Finally, Ms. Meads utilized secret offshore accounts in Panama in her tax evasion scheme – accounts that she never disclosed on her FBARs. By doing so, she granted to the IRS a very powerful weapon in the form of draconian FBAR penalties, not just criminal but also civil. This means that the IRS had a trump card in court to force Ms. Meads to agree to a guilty plea. In other words, with FBAR penalties as a major negotiation weapon, the IRS feels confident to press with the criminal charges for the entire case. While in the Meads case proving the rest of the charges might not have been very difficult, this is not the situation in a lot of other cases.

Contact Sherayzen Law Office for Professional Help With Disclosing Your Offshore Accounts in Panama and Any Other Foreign Country

If you have undisclosed foreign accounts or any other foreign assets, contact Sherayzen Law Office as soon as possible. Time may be of the essence, because an IRS investigation may prevent you from participating in any of the main Offshore Voluntary Disclosure initiatives.

With Sherayzen Law Office, you can feel confident that expertise, experience and convenience is on your side! We have helped hundreds of US taxpayers around the world to bring their tax affairs into full compliance with US tax laws, and We Can Help You!

Contact Us Today to Schedule Your Confidential Consultation!

Indianapolis FBAR Lawyer | Foreign Accounts Tax Attorney

One of the advantages of practicing US international tax law is that an international tax lawyer can offer his FBAR services throughout the United States. Why is this case? Why is an international tax lawyer who lives in Minneapolis considered as an Indianapolis FBAR Lawyer?

Indianapolis FBAR Lawyer: FBAR is Federal Law, Not State Law

The answer to the question above is not difficult and, in fact, very logical. FBAR is a part of US federal law and no local law plays a role in defining its requirements or its implementation. This means that any US international tax lawyer can offer FBAR services in any of the 50 states and the District of Columbia irrespective of his physical location. This further means that a lawyer in Minneapolis can be considered as an Indianapolis FBAR Lawyer even though he never visited the State of Indiana.

Indianapolis FBAR Lawyer Must Be a US International Tax Lawyer

It is worth emphasizing that an Indianapolis FBAR Lawyer must be a US international tax lawyer, not just any lawyer. This emphasis is very important because FBAR forms are part of the US international tax law and its penalty structure is deeply connected with a taxpayer’s overall tax compliance. In a voluntary disclosure situation, the relationship between FBAR and the overall US international tax compliance may play a determinative role in the legal position of a taxpayer.

A sophisticated reader might wonder why FBAR forms are part of the US international tax law if the FBAR was created as a result of the Bank Secrecy Act (i.e. Title 31 of the United States Code), whereas the entire Internal Revenue Code is located in Title 26 of the United States Code. The answer is not that simple and deserves a special article.

Nevertheless, I can provide a short answer here: FBAR is administered by the IRS and, as part of its historic evolution, the form became a tax enforcement mechanism.

Sherayzen Law Office Can Be Your Indianapolis FBAR Lawyer

If you are looking for an Indianapolis FBAR Lawyer, Sherayzen Law Office may be the perfect fit for you! Sherayzen Law Office is an international tax law firm that specializes in US tax compliance, including FBARs. We have profound knowledge of this area of law and the extensive experience in helping clients with international tax law issues, including offshore voluntary disclosures with respect to delinquent FBARs. We have helped hundreds of US taxpayers worldwide with their FBAR issues and we can help You!

Contact Sherayzen Law Office today to schedule Your Confidential Consultation!

Atlanta FBAR Lawyer | FATCA International Tax Attorney

Can a lawyer who resides in Minneapolis be considered an Atlanta FBAR Lawyer? What kind of law should such a lawyer practice? These are the two questions that I seek to answer in this article.

Atlanta FBAR Lawyer Definition: Legal FBAR Services Provided in Atlanta, Georgia

Let’s start with the first question. The term Atlanta FBAR Lawyer is comprised of two broad category of lawyers. The first category consists of international tax lawyers who reside in Atlanta and offer FBAR services to the residents of Atlanta. This is self-explanatory.

The second category is a bit more complicated because it is comprised of international tax lawyers who reside outside of Atlanta but offer FBAR services to the residents of Atlanta. At first, this does not seem logical, but, once we look into the legal nature of the FBAR, it makes perfect sense.

FBAR is a federal information return required by Title 31 of the United State Code. This is not a local requirement of Atlanta or the State of Georgia; they have no influence over the interpretation and the implementation of the FBAR requirement. This means that any licensed US international tax lawyer can offer FBAR services in any of the 50 states and the District of Columbia irrespective of his physical location.

Now, it is clear why an Atlanta FBAR lawyer can reside in Minneapolis – since the local law has no influence over FBARs, there is no special knowledge or access to courts associated with local lawyers. In essence, a lawyer in Minneapolis can offer FBAR legal services in Atlanta with the same ease as a lawyer who resides in Atlanta.

Atlanta FBAR Lawyer Must Be a US International Tax Lawyer

Now, we can turn to second question of the relevant practice area of law. Since FBAR constitutes a small part of US international tax law, there is a profound connection between FBAR and international tax law. In fact, it is this relationship between the FBAR and the rest of the international tax law requirements that apply in a particular case (based on the facts of that case) that determines the legal position of the taxpayer in a voluntary disclosure case.

This means that an Atlanta FBAR lawyer must also be an international tax lawyer – i.e. a lawyer who has profound knowledge of US international tax law requirements, including FBAR.

Sherayzen Law Office Can Be Your Atlanta FBAR Lawyer

Sherayzen Law Office specializes in FBARs and the US international tax law. Our legal and accounting team has a profound knowledge of this area of law and the extensive experience in helping clients with international tax law issues, including offshore voluntary compliance with respect to delinquent FBARs. We have helped hundreds of US taxpayers worldwide with their FBAR issues and we can help You!

Contact Sherayzen Law Office today to schedule Your Confidential Consultation!

Seattle FBAR Lawyer | IRS FATCA International Tax Attorney

I recently received a phone call from a person who was looking for a Seattle FBAR lawyer online and found my website. He asked me whether I can help him even though Sherayzen Law Office is based in Minneapolis, Minnesota. I responded to him: “yes, I can help you”.

This conversation brought to light an important topic of who should be considered a Seattle FBAR Lawyer and why an international tax lawyer based in Minneapolis can help a client in Seattle with FBAR issues.

Seattle FBAR Lawyer Definition: Legal FBAR Services Provided in Seattle, Washington

There are two categories of lawyers that fit the term Seattle FBAR Lawyer. The first category consists of US international tax lawyers who reside in Seattle and offer FBAR services to the residents of Seattle. The second category is comprised of US international tax lawyers who reside outside of Seattle but offer FBAR services to the residents of Seattle.

The first category is clear – if a lawyer resides in Seattle and offers FBAR services, he is considered to be a Seattle FBAR Lawyer. The question is: why is a lawyer who resides outside of Seattle still considered a Seattle FBAR lawyer? The answer lies in the legal nature of FBARs. FBAR is a federal information return, not a local requirement of Seattle or the State of Washington. This means that any licensed US international tax lawyer can offer FBAR services in any of the 50 states and the District of Columbia irrespective of his physical location. This is why a lawyer who resides in Minneapolis can offer FBAR legal services in Seattle with the same ease as a lawyer who resides in Seattle.

Seattle FBAR Lawyer Must Be US International Tax Lawyer

It should be emphasized that, while the residence of a Seattle FBAR Lawyer is not relevant, his area of practice is highly important. A Seattle FBAR lawyer must be an international tax lawyer – i.e. a lawyer who not only knows how to complete FBARS, but who has profound knowledge of US international tax law and the place the FBARs occupy in this law.

This emphasis is based on the fact that FBAR is only a small part of a much larger area of US international tax law. Indeed, there is a deep and complex relationship between the FBAR and international tax law that determines the legal position of a client and the potential voluntary disclosure strategies associated with delinquent FBARs.

This is why your Seattle FBAR lawyer should have deep knowledge of and extensive experience in both FBARs and all related US international tax laws and regulations.

Sherayzen Law Office Can Be Your Seattle FBAR Lawyer

Sherayzen Law Office is an international tax law firm that specializes in FBARs and international tax law. Our legal and accounting team has both: a profound knowledge of this area of law and extensive experience in helping clients with international tax law issues, including offshore voluntary compliance with respect to delinquent FBARs. We have helped hundreds of US taxpayers worldwide with their FBAR issues and we can help You!

Contact Sherayzen Law Office today to schedule Your Confidential Consultation!