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IRS Foreign Bank Accounts Stamford, Connecticut: The IRS continues its assault on hidden foreign bank accounts with its relentless prosecutions.

By
Education & Training with Tax Rep LLC

We frequently represent clients who have hidden bank accounts in foreign countries and would like to come forward and clean up their issue and sleep better at night.  Prior to 2009 we did through a voluntary disclosure with the IRS criminal division.  Since 2009 there have been two voluntary disclosure initiatives (the 2011 one ends August 31st).  If sleeping better at night and reduced penalties with reduced risk of criminal prosecution was not enough of an inducement, the recent headlines should be.

Reading the IRS announcements that have been streaming out of its criminal investigations division makes for interesting reading.  The cases include a litany of plea bargains and stiff sentences for those who failed to come forward.  These include the following:

  •  May 24, 2011 — Harry Abrahamsen, of Oradell, N.J., sentenced to three years probation, including 12 months of home confinement with electronic monitoring, and ordered to pay $600,000 in restitution and a civil penalty in excess of $300,000.
  •  April 21, 2011 — Ernest Vogliano, of Manhattan, N.Y., was sentenced to two years probation and ordered to pay a $940,000 civil penalty. He pleaded guilty on Dec. 22, 2010, to filing false tax returns and conspiring to defraud the Internal Revenue Service by hiding $4.9 million in an offshore bank account with UBS, AG.
  • March 11, 2011 — Richard Werdiger, of Purchase, N.Y., pleaded guilty to conspiring to defraud the IRS by hiding more than $7.1 million in a bank account at UBS AG.  As part of his plea agreement, Werdiger will pay a civil penalty of over $3.5 million from his failure to file Report of Foreign Bank or Financial Account (FBAR) forms.


  • March 4, 2011 — Arthur Joel Eisenberg, of Seattle, Wash., was sentenced to serve three years’ probation and to pay a $2.1 million penalty for failing to file a Report of Foreign Bank or Financial Account (FBAR) form. 

  • Nov. 10, 2010 — Sybil Nancy Upham, of Manhattan, N.Y., pleaded guilty to conspiring to defraud the IRS and subscribing to false federal income tax returns. As part of her plea agreement, Upham has agreed to pay over $5.5 million in penalties for failure to file FBARs. 
  •  Sept. 21, 2010 — Jules Robbins, of New York, N.Y., who owned and operated watch distribution companies, was sentenced to one year probation and ordered to pay a civil FBAR penalty of $20.8 million.
  •  Sept. 17, 2010 — Federico Hernandez, of New York, N.Y., was sentenced to 12 months in prison, six months home confinement, and ordered to pay a civil FBAR penalty of $4.4 million. 
  •  Feb. 4, 2010 — Jack Barouh of Golden Beach, Fla., pleaded guilty to filing a false tax return. Barouh admitted to filing a false tax return for 2007 in which he failed to report a foreign bank account. He was sentenced to 10 months in prison and ordered to pay all taxes, interest and penalties due and owing.

  We recommend clients who have a foreign bank account who have (willingly or not) failed to file their foreign bank account reports (FBARs) with their tax returns and/or picked up the income generated from these accounts come forward and deal with the issue while they still can civilly.   

  If you have any questions regarding a foreign bank account in Stamford, Connecticut or elsewhere do not hesitate to contact me at (203) 602-5550 or by email at egreen@convicerpercy.com.

  

Eric L. Green, Esq.

Convicer, Percy & Green, LLP

60 Long Ridge Rd., Suite 202

Stamford, CT 06902

Ph. (203) 602-5550

Fax (203) 286-1311

www.convicerpercy.com

 

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