Foreign Bank Accounts/Offshore Assets Lawyer in Washington DC
One of the IRS' top priorities is combating offshore tax evasion, the filing of false tax returns, and willful failure to file Reports of Foreign Bank Financial Accounts (FBAR). The IRS is committed to pursuing people hiding income offshore, understating their federal taxes, failing to disclose their foreign bank accounts and other financial accounts.
You should contact Attorney Bruce E. Gardner of The Gardner Law Firm, P.C. for a consultation to determine your criminal exposure if you have:
- An offshore account,
- Did not reported income from a foreign account on your U.S. tax return,
- Never filed Form TD F90-22; Form 3520, or Form 54711;
- Never checked the box on Schedule B (Form 1040);
- Earned income abroad;
- An interest in a foreign trust, corporation, or partnership;
- Signature authority over foreign assets
On August 19, 2009, the IRS and Department of Justice negotiated an agreement with Swiss bank UBS that will result in the IRS receiving an unprecedented amount of information on U.S. accountholders. Prior to this agreement, the IRS and Department of Justice had successfully prosecuted four UBS accountholders whose information was provided to the IRS as part of the Deferred Prosecution Agreement in which the bank admitted to helping U.S. taxpayers hide accounts from the IRS. As part of this agreement, UBS agreed to provide the U.S. government with the identities and account information of certain United States customers of UBS' cross-border business.
As recently as July 28, 2009, 70 year old Jeffrey P. Chernick of Stanfordville, N.Y. was convicted of filing a false individual 2007 income tax return and failing to disclose he had an interest in or signature authority over a financial account at UBS AG. Chernick was the beneficial owner of approximately $8 million in offshore assets which were maintained in accounts in the name of nominee entities.
Contact us to schedule a consultation regarding your criminal tax law concerns.