Offshore Bank Accounts – IRS Tax Help – Former IRS, Attorneys – Offshore Specialists – South Florida Tax Consultants

July 31, 2012
Written by: Fresh Start Tax

There is nothing wrong with having Offshore Bank Accounts. However the reporting of the Offshore Bank Accounts has changed. It is very important that everyone take note of the new changes as well as keep up with the ever changing tax laws in the area of tax compliance and tax reporting for Offshore Bank Accounts.

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So, who Must File an FBAR

Listen up,  all United States persons are required to file an FBAR if:

1.  The United States person had a financial interest in or signature authority over at least one financial account located outside of the United States; and,
2. The aggregate value of all foreign financial accounts exceeded $10,000 at any time during the calendar year to be reported.

United States person means United States citizens;United States residents;entities, including but not limited to, corporations, partnerships, or limited liability companies created or organized in the United States or under the laws of the United States; and trusts or estates formed under the laws of the United States.

We are not trying to scare anybody here however the Feds are cracking the whip on illegal and unreported Offshore Bank Accounts. Recently Wolfgang Ressel was convicted for failing to disclose.

See the report source IRS.gov modified for blog.

Wolfgang Ressel of Ft. Lauderdale, Fla., pleaded guilty today in the U.S. District Court in the Southern District of Florida to filing a false tax return for 2007, the Justice Department and Internal Revenue Service.

According to the court documents, Ressel, a U.S. citizen, maintained bank accounts at UBS AG in Switzerland, which he failed to report on his 2002 through 2007 personal income tax returns.

Ressel also failed to file a Report of Foreign Bank and Financial Accounts (FBAR) for these same years.

What happened.

In 2002, Ressel opened a UBS numbered investment account in the nominee name of a foreign entity, Neptune Trust, with an opening balance of approximately $4–5 million.   In around 2004, this account and sub accounts were transferred into the nominee name of another foreign entity, Cyan United, and traded in U.S. and foreign securities. The defendant met with a Swiss banker periodically to discuss the performance of his accounts.

Court Records.

Court records also established that, dating back to the 1980s and up through the late 2000s, Ressel held accounts at different times at Bank Wegelin and another Swiss bank (Bank A) into which he deposited foreign proceeds from his business, yet which he neither reported on his tax returns nor on the required FBARs.

In the early 2000s, the foreign account at Bank A was put into the nominee name of Cyan United. A Swiss money manager made investments on Ressel’s behalf and met with the defendant periodically to discuss the performance of the account. In 2008 and 2009, during which period the defendant was aware of the government’s grand jury investigation into his foreign UBS accounts, the defendant disclosed only the existence of the UBS accounts on his tax returns for those years and did not report the other Swiss account.

Plea Agreement

The plea agreement includes a tax loss of $312,802.95 for 2002 through 2007, and an FBAR penalty owing to the U.S. Treasury of $5,750,933.99, which is 50 percent of the 2007 unreported foreign bank accounts year-end balance of over $11 million.

Possible sentence

Ressel faces a potential maximum prison term of three years and a fine of up to $250,000. A sentencing date has not been set.

Should you be in this situation and need immediate tax help call us today.

All information can be under attorney client privilege.

Offshore Bank Accounts – IRS Tax Help – Former IRS, Attorneys – Offshore Specialists – South Florida Tax Consultants

 

Filed Under: FBAR | Tax Lawyer
Tags: IRS

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