Under the Bank Secrecy Act, U.S. residents or a person in and doing business in the United States must file a report with the U.S. Treasury if he or she has a financial account in a foreign country with a value exceeding $10,000 at any time during the calendar year. Taxpayers comply with this law by noting the account on their tax return and by filing Form 90-22.1, the Foreign Bank and Financial Account Report (FBAR). Willfully failing to file an FBAR report can be punished under both civil and criminal law.
IRS Criminal Investigation (CI) is comprised of approximately 4,400 employees worldwide, approximately 2,600 of which are special agents whose investigative jurisdiction includes tax, money laundering and Bank Secrecy Act laws. While other federal agencies also have investigative jurisdiction for money laundering and some bank secrecy act violations, IRS is the only federal agency that can investigate potential criminal violations of the Internal Revenue Code.
The total number of audits of individual returns increased in 2010. Those who earned less than $200,000 had about a 1 percent chance of being audited. Those with incomes of $200,000 and more had about a 3 percent chance of being audited.
Arnstein & Lehr Chicago Partner Robert E. McKenzie was interviewed by First Business News for its April 11 broadcast. During the interview Mr. McKenzie discussed the IRS tax probe of HSBC Bank off-shore accounts in India. According to Mr. McKenzie,…
Custom Search Arnstein & Lehr Chicago Partner Robert E. McKenzie recently authored a piece titled, "IRS and Offshore Accounts." It discusses the IRS' new 2011 Voluntary Disclosure Initiative (OVDI) for taxpayers to disclose their unreported offshore accounts. To read "IRS…
Video of Robert E. McKenzie Bloomberg interview regarding offshore accounts Click here Custom Search
IRS & Offshore Account Holders
IRS will step up its efforts to find Americans utilizing tax haven banks. Since September 11 the U. S. Financial Crimes Enforcement Network has developed a coordinated program to find money laundering, foreign banking activity, and tax evasion. In most white collar crime cases the Justice Department offers plea bargains to individuals like Birkenfeld in return for cooperation in charging others involved in illegal activity. Therefore with increased resources being allocated to seeking out foreign bank activities by Americans we can anticipate will the first of many bankers who cooperate to reduce their potential jail time.
Tax attorney Robert E. McKenzie comments as IRS unlocks UBS vault hiding Americans evading taxes. IRS Unlocks UBS Vault Custom Search