The Department of Justice and local United States Attorneys’ Offices continue to zealously prosecute numerous…
12 October, 2015
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By Parag P. Patel, Esq. | Updated November 4, 2026In 2015, this post catalogued IRS and DOJ announcements of successful offshore enforcement actions. Those press releases have since moved or been archived. For current analysis of federal offshore and FBAR enforcement, see the posts below.
Recent enforcement coverage
- The Enforcement Surge: What the DOJ and IRS Campaign Means for Tax Professionals and Their Clients — the DOJ and IRS Criminal Investigation’s national tax enforcement surge resulting in over $490 million in tax fraud cases.
- FBAR Willfulness, Recklessness, and the Excessive Fines Defense: Key Takeaways from United States v. Rund
- FBAR Enforcement and Penalty Analysis: United States v. Niksich
- The High Price of Payroll Tax Non-Compliance: Lessons from United States v. Pitts
Official sources
- IRS Criminal Investigation Voluntary Disclosure Practice
- Streamlined Filing Compliance Procedures
- U.S. Department of Justice — Swiss Bank Program
Parag P. Patel, Esq. brings over three decades of experience to individuals and businesses facing complex tax problems. Holding advanced degrees from Georgetown University Law Center (J.D.) and New York University School of Law (LL.M. in Tax Law), the nation’s top tax programs, Mr. Patel delivers sophisticated and creative strategies in complicated federal and state audits, penalty abatements, and foreign asset/income reporting. His practice emphasizes international tax matters, specifically foreign financial account reporting (FBAR), voluntary disclosures, and penalty defense.
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