Nardone Law Group’s experienced tax attorneys, located in Columbus, Ohio, routinely advise taxpayers on their U.S. tax reporting obligations regarding foreign financial accounts and the importance of reporting previously undisclosed foreign accounts. See our prior articles discussing the IRS’ Offshore Voluntary Disclosure Program and the IRS’ Streamlined Filing Compliance Procedures program.
This article discusses the IRS’ continued enforcement and scrutiny of taxpayers related to Offshore Accounts, including the taxpayers’ tax and investment professionals. In many instances, the IRS is more interested, or as interested, in going after the tax attorneys, tax accountants, investment advisors, or bankers that help the taxpayers facilitate their tax evasion activities. The IRS’ interest in the professional themselves is highlighted in the recent prosecution and sentencing of two former Credit Suisse AG bankers. The idea is that some taxpayers would not be willing to, or able to, participate in tax evasion activities without the aiding and abetting of their professional advisors. Thus, if we deter the professional from participating in certain activities, we then deter the taxpayer.
Indictment and Sentencing
In this particular case, the bankers assisted taxpayers with undisclosed foreign accounts from reporting earnings on those accounts. The bankers’ assistance included the use of secret accounts and shell companies used to conceal the underlying activity and the ownership of the accounts. In some instances, taxpayers did not even receive monthly or yearly statements as to the amounts in their accounts at any particular time. That is, all parties involved wanted to avoid any sort of paper trail. The taxpayers would likely not have been able to achieve the concealment without the aiding and abetting of the bankers. The bankers ultimately plead guilty and were recently sentenced. In the recent sentencing, a federal judge sentenced both bankers to five years of unsupervised probation for their roles in helping numerous taxpayers hide earnings from taxing authorities. Both bankers were also fined for their involvement. The light sentence for both bankers took into account many facets of the case, including the bankers’ cooperation with the government and their family and personal circumstances. See the statement of facts from Andreas Bachmann’s indictment and those from Josef Dorig’s indictment for additional and specific detail.
Contact Nardone Law Group
Nardone Law Group frequently represents individuals and businesses in federal and state tax issues, including defending individuals and businesses being investigated and prosecuted for tax evasion activities, as well as participating in the IRS’ Offshore Voluntary Disclosure Programs and the Streamlined Filing Compliance Procedures. If you have been contacted by the IRS, or have an undisclosed foreign account, asset, or entity, contact an experienced Nardone Law Group tax attorney today. We will thoroughly review your case to determine what options and alternatives are available.