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International Law Lawyers USA - Recent Legal Articles

  • Willfulness and the Civil FBAR Penalty
      by Brown, PC

    In 2008, when it was revealed that wealthy individuals around the world were utilizing accounts and trusts in Liechtenstein to evade taxes, the United States initiated a coordinated effort with foreign governments to combat tax evasion through the use of offshore trusts and accounts. The U.S. Department of Justice (DOJ) has since launched criminal investigations of several foreign banks, many of which are ongoing.

  • Extra! Extra! Read All About It! IRS Commissioner Announces That Changes Are In the Offing For OVDP 2012

    On June 3, 2014 the new IRS Commissioner, John A. Koskinen, gave a speech before the International Business - OECD International Tax Conference. His speech covered the history of the offshore enforcement initiative since the UBS debacle in 2009. His remarks acknowledge what most professionals in the tax community have recognized since the inception: that OVDP needs more tweaking in order to meet the overall goals of enforcement and fairness.

  • FBAR and FATCA – Two Abbreviations That Can Wrap You Around the IRS Axle

    FBAR and FATCA are two important abbreviations for those who have overseas financial interests. Failure to file the FBAR report, in view of the IRS’s continuing application of FATCA, can get you into what old military veterans used to call FUBAR.

  • The Rules Governing Taxation of Foreign Nationals

    Below are the rules governing taxation of foreign nationals.

  • “FATCA” Law is Striking Fear into Foreign Banks

    Law That May Reduce Tax Evasion Goes Into Effect On July 1 The Foreign Account Tax Compliance Act (FATCA) became law in the United States in 2010, but the clock is still ticking on its implementation. The clock will stop ticking on July 1, 2014.

  • Lifting the Veil on the Civil FBAR Penalty

    It should come as no surprise that the IRS has authority to assess FBAR civil penalties. However, what might come as a surprise is that an FBAR violation doesn’t automatically mean that a penalty will be asserted. Why not?

  • No Laughing Matter: The Criminal Consequences of Failing to Report Foreign Bank Accounts

    United States citizens, residents and other persons must annually report their direct or indirect financial interest in, or signature authority over, a financial account that is maintained with a financial institution located in a foreign country if, for any calendar year, the aggregate value of all foreign accounts exceeded $ 10,000 at any time during the year.

  • White Collar Crime: Entrapment and Ignorance of the Law Can Snare the Unwary

    The most common white-collar offenses run the gamut of nonviolent crimes from antitrust violations to money laundering. The FBI estimates that white-collar crime costs the United States more than $300 billion annually. These estimates do not take into account cases where aggressive and ambitious prosecutors snare an unwary person, who eventually pleads guilty in the face of intimidation and threats. Then there is the plethora of regulations where ignorant noncompliance is, nevertheless, a crime.

  • A Primer on the Foreign Earned Income Exclusion

    Ordinarily, the United States taxes U.S. citizens and resident aliens on their worldwide income, even when they live and work abroad for an extended period of time. To provide some relief, a U.S. citizen or resident who meets certain requirements can elect to exclude from U.S. taxation a limited amount of foreign earned income plus a housing cost amount. A double tax benefit is not allowed, however, and a taxpayer cannot claim a credit for foreign income taxes related to excluded income.

  • More U.S. Taxpayers Admit to Secret Swiss Accounts

    Why Swiss Bank Clients Who Can’t Stand the Heat Are Getting Out of the Kitchen.


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