Entries by Manager

New Convictions for Helping Hide Millions in Israeli Offshore Accounts

On December 19, 2014, a federal jury sitting in Los Angeles convicted two California tax return preparers of one count of conspiracy to defraud the Internal Revenue Service (IRS) and two counts of willfully failing to file a Report of Foreign Bank and Financial Accounts (FBAR) with respect to secret Israeli Offshore Accounts. Israeli Offshore […]

IRS Criminal Investigation Co-Hosts First International Criminal Tax Symposium

The Internal Revenue Service Criminal Investigation Division (IRS-CI) and Her Majesty’s Revenue & Customs (HMRC) co-hosted a three-day International Criminal Tax Symposium in Washington, D.C. on January 27 – 29, 2015. The symposium focused on combating offshore tax evasion and international financial crimes. It is worth mentioning that delegates from criminal tax and enforcement programs […]

Streamlined Domestic Offshore Compliance Process

In a previous article, I discussed the eligibility requirement with respect to the Streamlined Domestic Offshore Procedures. In this article, I would like to explore the specific filing requirements under the Streamlined Domestic Offshore Procedures. As a side note, it is important to emphasize that this is just an educational article on the general overview […]

Title 26 Miscellaneous Offshore Penalty under SDOP

The Title 26 Miscellaneous Offshore Penalty (“Miscellaneous Offshore Penalty”) is one of the most critical aspects of the Streamlined Domestic Offshore Procedures (“SDOP”). In this article, I want to conduct a general overview of how the Miscellaneous Offshore Penalty is calculated. As a side note, it is important to keep in mind that this is an […]