The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) on Monday said it has developed an electronic filing system for Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR). The reports can now be
On July 14, 2011, Credit Suisse received a letter notifying it that it is a target of a Justice Department investigation. A target letter is significant. It likely means that a considerable level of investigation has already been
The IRS recently posted guidance in its OVDI FAQs (#51) whether taxpayers should opt out of the 2011 Voluntary Disclosure Initiative’s (the “OVDI”) civil penalty structure. Taxpayers who participate in the OVDI, but feel that their
Our firm recently informally met with a US Department of Justice official (name withheld because official was not authorized to officially speak) in Washington DC regarding the pending summons served on HSBC India to reveal
Our office is advising dozens of clients (including many HSBC customers) regarding offshore accounts, all of whom may be subject to large unfair penalties. Finally it appears that someone in government is realizing the unfairness
