FBAR_OVDI & 419 Plans Litigation FBAR,OVDI,OPT-OUT,AMNESTY412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
Monday, December 2, 2013 Fbar Ovdi Want to Go to Jail? Offshore Tax. Lance Wallach, expert witness. The Federal government is aggressively pursuing taxpayers with undisclosed foreign accounts and unreported foreign income using information furnished by the foreign banks and other sources. If you have not yet applied for the Offshore Voluntary Disclosure Program, Recent convictions involving UBS Clients:
1. Jan. 30, 2012 - Stephen M. Kerr, Michael Quiel and Christopher M. Rusch were charged in Phoenix, Ariz., with conspiracy to defraud the IRS for concealing millions of dollars in assets in numerous secret Swiss bank accounts held at UBS and elsewhere.
2. Jan. 20, 2012 - Kenneth Heller, of New York, N.Y., was sentenced to 45 days in prison and two years of supervised release. Heller pleaded guilty to income tax evasion in June 2011 and admitted to hiding more than $26.4 million in a bank account at UBS AG. He has agreed to pay a civil penalty of over $9.8 million.
Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. He writes about 412(i), 419, and captive insurance plans. He speaks at more than ten conventions annually, writes for more than 20 publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Pubic Radio's All Things Considered, and others. Lance has written numerous books including Protecting Clients from Fraud, Incompetence and Scams published by John Wiley and Sons, Bisk Education's CPA's Guide to Life Insurance and Federal Estate and Gift Taxation, as
Help with Common IRS Problems: FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accoun... Help with Common IRS Problems: FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accoun...: FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accounts and Foreign Income Att... : You may want to think about participation in the IRS’ offsh...
Summary of Federal Laws
Tax Miscellaneous Tax Issues Compliance Partners
VP for Finance and Treasurer Related Policies
Tax Compliance Foreign Bank Accounts and Tax Filings 31 USC 5314(a) 31 CFR § 1010 US institutions and citizens that have an ownership interest in foreign bank accounts, or US citizens with signature authority over a foreign bank account have to file form TD F 90.22-1 (FBAR). The latter must report the account on an FBAR even if the foreign financial account is reported on an FBAR filed by the owner of the account (or other person that has a financial interest in the account). This form must be filed by June 30 of the year following any year during which they possessed signature or other authority over, or had a $ interest in foreign financial accounts whose value exceeded $10,000 at a
Tax Compliance Foreign Bank Accounts and Tax Filings 31 USC 5314(a)
31 CFR § 1010 US institutions and citizens that have an ownership interest in foreign bank accounts, or US citizens with signature authority over a foreign bank account have to file form TD F 90.22-1 (FBAR). The latter must report the account on an FBAR even if the foreign financial account is reported on an FBAR filed by the owner of the account (or other person that has a financial interest in the account). This form must be filed by June 30 of the year following any year during which they possessed signature or other authority over, or had a $ interest in foreign financial accounts whose value exceeded $10,000 at any time during the calendar year.The IRS FBAR page has an update to reporting deadlines and further clarification and extensions. There have been more than a few. See especially FinCEN Notice 2011-1 for an extension until June 30, 2012 in certain circumstances.
McDermott Will and Emery posted a chart on July 1, 2011 with various filing deadlines and an explanation as to who was covered by the various rules. See FBAR Filing Deadline for Extensions for Certain Individuals with Signature Authority.
FBAR Final Rule; Amendment to the Bank Secrecy Act Regulations-Reports of Foreign Financial Accounts, 76 Fed. Reg. 10234, Feb. 24, 2011, Effective March 28, 2011
The final rules clarify who has the signature authority over a foreign bank account as follows:
Signature or other authority means the authority of an individual (alone or in conjunction with another) to control the disposition of money, funds or other assets held in a financial account by direct communication (whether in writing or otherwise) to the person with whom the financ
Lance Wallach: Articles: INVESTMENT NEWS: 419e, 412i ... www.taxaudit419.com/FBARInternationalTaxes.html Idea.com August 2011. Lance Wallach FBAR International Taxes The FBAR Deadline is here. Filing deadline for the IRS's offshore tax amnesty (called the FBAR/OVDI LANCE WALLACH multinationaltaxesfbarovdi.blogspot.com/ Mar 4, 2014 - June 30 2014 is the annual deadline for U.S. taxpayers, (including resident aliens) ... Failure to file and for the IRS to receive an FBAR by June 30 may result in ... There was the 2009, 2011, 2012 and now the 2013 programs.
FBAR_OVDI & 419 Plans Litigation
ReplyDeleteFBAR,OVDI,OPT-OUT,AMNESTY412i, 419e plans litigation and IRS Audit Experts for abusive insurance based plans deemed reportable or listed transactions by the IRS.
Monday, December 2, 2013
Fbar Ovdi Want to Go to Jail? Offshore Tax. Lance Wallach, expert witness.
The Federal government is aggressively pursuing taxpayers with undisclosed foreign accounts and unreported foreign income using information furnished by the foreign banks and other sources. If you have not yet applied for the Offshore Voluntary Disclosure Program, Recent convictions involving UBS Clients:
1. Jan. 30, 2012 - Stephen M. Kerr, Michael Quiel and Christopher M. Rusch were charged in Phoenix, Ariz., with conspiracy to defraud the IRS for concealing millions of dollars in assets in numerous secret Swiss bank accounts held at UBS and elsewhere.
2. Jan. 20, 2012 - Kenneth Heller, of New York, N.Y., was sentenced to 45 days in prison and two years of supervised release. Heller pleaded guilty to income tax evasion in June 2011 and admitted to hiding more than $26.4 million in a bank account at UBS AG. He has agreed to pay a civil penalty of over $9.8 million.
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Lance Wallach
Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty of teaching professionals, is a frequent speaker on retirement plans, financial and estate planning, and abusive tax shelters. He writes about 412(i), 419, and captive insurance plans. He speaks at more than ten conventions annually, writes for more than 20 publications, is quoted regularly in the press and has been featured on television and radio financial talk shows including NBC, National Pubic Radio's All Things Considered, and others. Lance has written numerous books including Protecting Clients from Fraud, Incompetence and Scams published by John Wiley and Sons, Bisk Education's CPA's Guide to Life Insurance and Federal Estate and Gift Taxation, as
IRS tax relief firm, Lance Wallach, speaking
ReplyDeleteWednesday, March 5, 2014
Help with Common IRS Problems: FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accoun...
Help with Common IRS Problems: FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accoun...: FBAR/OVDI LANCE WALLACH: FBAR Offshore Bank Accounts and Foreign Income Att... : You may want to think about participation in the IRS’ offsh...
Summary of Federal Laws
Tax
Miscellaneous Tax Issues
Compliance Partners
VP for Finance and Treasurer
Related Policies
Tax Compliance
Foreign Bank Accounts and Tax Filings
31 USC 5314(a)
31 CFR § 1010
US institutions and citizens that have an ownership interest in foreign bank accounts, or US citizens with signature authority over a foreign bank account have to file form TD F 90.22-1 (FBAR). The latter must report the account on an FBAR even if the foreign financial account is reported on an FBAR filed by the owner of the account (or other person that has a financial interest in the account). This form must be filed by June 30 of the year following any year during which they possessed signature or other authority over, or had a $ interest in foreign financial accounts whose value exceeded $10,000 at a
Lance Wallach
ReplyDeleteShared publicly - Mar 5, 2014
Summary of Federal Laws
Tax
Miscellaneous Tax Issues
Compliance Partners
VP for Finance and Treasurer
Related Policies
Tax Compliance
Foreign Bank Accounts and Tax Filings
31 USC 5314(a)
31 CFR § 1010
US institutions and citizens that have an ownership interest in foreign bank accounts, or US citizens with signature authority over a foreign bank account have to file form TD F 90.22-1 (FBAR). The latter must report the account on an FBAR even if the foreign financial account is reported on an FBAR filed by the owner of the account (or other person that has a financial interest in the account). This form must be filed by June 30 of the year following any year during which they possessed signature or other authority over, or had a $ interest in foreign financial accounts whose value exceeded $10,000 at any time during the calendar year.The IRS FBAR page has an update to reporting deadlines and further clarification and extensions. There have been more than a few. See especially FinCEN Notice 2011-1 for an extension until June 30, 2012 in certain circumstances.
McDermott Will and Emery posted a chart on July 1, 2011 with various filing deadlines and an explanation as to who was covered by the various rules. See FBAR Filing Deadline for Extensions for Certain Individuals with Signature Authority.
FBAR Final Rule; Amendment to the Bank Secrecy Act Regulations-Reports of Foreign Financial Accounts, 76 Fed. Reg. 10234, Feb. 24, 2011, Effective March 28, 2011
The final rules clarify who has the signature authority over a foreign bank account as follows:
Signature or other authority means the authority of an individual (alone or in conjunction with another) to control the disposition of money, funds or other assets held in a financial account by direct communication (whether in writing or otherwise) to the person with whom the financ
Lance Wallach: Articles: INVESTMENT NEWS: 419e, 412i ...
ReplyDeletewww.taxaudit419.com/FBARInternationalTaxes.html
Idea.com August 2011. Lance Wallach FBAR International Taxes The FBAR Deadline is here. Filing deadline for the IRS's offshore tax amnesty (called the
FBAR/OVDI LANCE WALLACH
multinationaltaxesfbarovdi.blogspot.com/
Mar 4, 2014 - June 30 2014 is the annual deadline for U.S. taxpayers, (including resident aliens) ... Failure to file and for the IRS to receive an FBAR by June 30 may result in ... There was the 2009, 2011, 2012 and now the 2013 programs.