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On March 20, 2014, the politics and FBAR criminal enforcement met again in a new case, U.S. v. Victor Lipukhin – a case of continuous interest for a Swiss Accounts IRS Tax Lawyer. While the timing is most likely driven by politics, this case also resulted from the fallout of the UBS 2009 settlement; under […]
The Swiss Bank letters continue to pour into the mailboxes of U.S. taxpayers with bank and financial accounts in Switzerland as the April 30th deadline approaches for many Swiss banks that participate in the ongoing U.S. Department of Justice (“DOJ”) The Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (the “Program”). In an […]
There used to be a time when quiet disclosures with respect to offshore income and accounts were routinely recommended by accountants and even attorneys. Even as the tide turned against non-compliant U.S. taxpayers with offshore accounts in 2008-2009 with the spectacular IRS success in the UBS case and the announcement of the 2009 Offshore Voluntary […]
Choosing the right Offshore Voluntary Disclosure Lawyer is a very important decision that may determine the fate of your entire offshore voluntary disclosure case. While making this choice, I recommend that you consider the following five main factors while choosing your Offshore Voluntary Disclosure Lawyer. 1. Areas of Practice of Your Offshore Voluntary Disclosure Lawyer […]
This Lebanon FATCA update is intended to provide a broad analysis of the impact of the U.S. Foreign Account Tax Compliance Act (“FATCA”) on the numerous U.S. accountholders in Lebanon. Lebanon FATCA: Background Information The Lebanese banking secrecy rules, commonly known as the “1956 Law”, have earned the country the unofficial title of the “Switzerland […]