International Tax
type: channel
date: 2024-01-03T18:08:33Z
update period: hourly
update frequency: 1
update base: 2000-01-01T12:00+00:00
generator agent: https://wordpress.org/
items: U.S. Beneficial Ownership Information Registry Now Accepting Reports
items: Be Aware of Currency Investment Scams
items: HISTORY OF FOREIGN BANK ACCOUNTS AND U.S. REPORTING
items: Department of the Treasury’s Office of Foreign Assets Office of Foreign Assets Control, Treasury.
items: ROBERT T. BROCKMAN Tax Case
items: New Hampshire Man Pleads Guilty To Filing False Tax Return
items: Former Florida Resident Indicted for Tax Evasion and Failing to Report Foreign Bank Accounts
items: Los Angeles Man Pleads Guilty to Not Reporting over $1 Million Held in Israeli Offshore Accounts
items: Azizur Rahman Indictment FBAR case
items: A professor and researcher at Massachusetts Institute of Technology (MIT)

U.S. Beneficial Ownership Information Registry Now Accepting Reports
type: item
creator: Michael Nelson
date: 2024-01-03T18:04:56Z
subject: FinCEN
subject: Tax Compliance
description: Today, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) began accepting beneficial ownership information reports. The bipartisan Corporate Transparency Act, enacted in 2021 to curb illicit finance,...
encoded: Today, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) began accepting beneficial ownership information reports. The bipartisan Corporate Transparency Act, enacted in 2021 to curb illicit finance, requires many companies doing business in the United States to report information about the individuals who ultimately own or control them. Filing is simple, secure, and free of charge. Beneficial ownership information reporting is not an annual requirement. A report only needs to be submitted once, unless the filer needs to update or correct information. Companies that are required to comply must file by the following deadlines: Reporting companies created or registered to do business in the United States before January 1, 2024, must file by January 1, 2025. Reporting companies created or registered to do business in the United States in 2024 have 90 calendar days to file after receiving actual or public notice that their company’s creation or registration is effective. To find out more about the reporting process, visit https://www.fincen.gov/boi.

Be Aware of Currency Investment Scams
type: item
creator: Michael Nelson
date: 2023-09-08T16:35:31Z
subject: Asset Protection Planning
subject: Bitcoin
subject: Featured Articles
subject: FinCEN
description: BE AWARE OF CURRENCY INVESTMENT SCAMS. September 2023, The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an alert to U.S. financial institutions and the broader public...
encoded: BE AWARE OF CURRENCY INVESTMENT SCAMS. September 2023, The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an alert to U.S. financial institutions and the broader public to bring attention to a prominent virtual currency investment scam called “pig butchering.” These scams are referred to as “pig butchering” because they resemble the practice of fattening a hog before slaughter. The victims in this situation are referred to as “pigs” by the scammers who leverage fictitious identities, the guise of potential relationships, and elaborate storylines to “fatten up” the victim into believing they are in trusted partnerships. The scammers then refer to “butchering” or “slaughtering” the victim after victim assets are stolen, causing the victims financial and emotional harm. In many cases, the “butchering” phase involves convincing victims to invest in virtual currency, or in some cases, over-the-counter foreign exchange schemes —all with the intent of defrauding them of their investment. Pig butchering scams are largely perpetrated by criminal organizations based in Southeast Asia who use victims with the description “Pig Butchering.” Multiple U.S. law enforcement sources estimate victims in the United States have lost billions of dollars to these scams and other virtual currency investment frauds. <img fetchpriority="high" decoding="async" class="alignnone wp-image-5673 size-full" src="https://offshorecompliance.com/wp-content/uploads/2023/09/currency.jpg" alt="" width="900" height="600" srcset="https://offshorecompliance.com/wp-content/uploads/2023/09/currency.jpg 900w, https://offshorecompliance.com/wp-content/uploads/2023/09/currency-300x200.jpg 300w, https://offshorecompliance.com/wp-content/uploads/2023/09/currency-768x512.jpg 768w" sizes="(max-width: 900px) 100vw, 900px" /> This alert explains the pig butchering scam methodology and provides red flag indicators to assist with identifying and reporting related suspicious activi…

HISTORY OF FOREIGN BANK ACCOUNTS AND U.S. REPORTING
type: item
creator: Michael Nelson
date: 2023-08-15T18:51:10Z
subject: Asset Protection Planning
subject: Featured Articles
subject: FinCEN
subject: Tax Cases
subject: Tax Compliance
subject: Tax Planning
subject: Tax Treaty
description: Below is the history of the Report of Foreign Bank and Financial Accounts, hereinafter also referred to as FBAR and its relationship to the Financial Crimes Enforcement Network (FinCEN), U.S....
encoded: Below is the history of the Report of Foreign Bank and Financial Accounts, hereinafter also referred to as FBAR and its relationship to the Financial Crimes Enforcement Network (FinCEN), U.S. Treasury. I. Statutory and Regulatory Provisions The legislative framework generally referred to as the Bank Secrecy Act (BSA) consists of the Currency and Foreign Transactions Reporting Act of 1970, as amended by the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (USA PATRIOT Act), Public Law 107–56 (October 26, 2001), and other legislation, including the Anti-Money Laundering Act of 2020 (AML Act).[2] The BSA is codified at 12 U.S.C. 1829b, 12 U.S.C. 1951–1960, and 31 U.S.C. 5311–5314 and 5316–5336, and notes thereto, with implementing regulations at 31 CFR chapter X. The BSA authorizes the Secretary of the Treasury (the “Secretary”), inter alia, to require financial institutions to keep records and file reports that are determined to have a high degree of usefulness in criminal, tax, or regulatory matters, risk assessments or proceedings, or in the conduct of intelligence or counter-intelligence activities to protect against international terrorism, and to implement AML programs and compliance procedures.[3] Regulations implementing the BSA appear at 31 CFR chapter X. The authority of the Secretary to administer the BSA has been delegated to the Director of FinCEN.[4] Under 31 U.S.C. 5314, the Secretary “shall require a resident or citizen of the United States or a person in, and doing business in, the United States, to . . . keep records and file reports, when the resident, citizen, or person makes a transaction or maintains a relation for any person with a foreign financial agency.” The term “foreign financial agency” encompasses the activities found in the statutory definition of “financial agency,” [5] notably, “a person acting for a person as a financial institution, bailee, depository trustee, o…

Department of the Treasury’s Office of Foreign Assets Office of Foreign Assets Control, Treasury.
type: item
creator: Michael Nelson
date: 2023-08-15T18:47:38Z
subject: Asset Protection Planning
subject: Featured Articles
subject: FinCEN
subject: Tax Compliance
subject: Tax Planning
description: ACTION: Russian Harmful Foreign Activities Sanctions directive SUMMARY: The directive, issued pursuant to an April 15, 2021 Executive Order. DATES: Directive 4 (as amended) under Executive Order 14024, “Prohibitions Related...
encoded: ACTION: Russian Harmful Foreign Activities Sanctions directive SUMMARY: The directive, issued pursuant to an April 15, 2021 Executive Order. DATES: Directive 4 (as amended) under Executive Order 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” was issued on May 19, 2023. Background On May 19, 2023, the Director of OFAC issued Directive 4 (as amended) “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation”, includes a new Reports section, to require that United States persons who are in possession or control of property in which any entity determined to be subject to the prohibitions of Directive 4 (as amended) has an interest of any nature whatsoever, direct or indirect, must submit a report to OFAC on or before June 18, 2023, and annually thereafter by June 30, 2023, and reflects technical and other non-substantive changes. OFFICE OF FOREIGN ASSETS CONTROL Directive 4 (as Amended) [1] Under Executive Order 14024 Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation Pursuant to sections 1(a)(iv), 1(d), and 8 of Executive Order 14024, “Blocking Property With Respect To Specified Harmful Foreign Activities of the Government of the Russian Federation” (the “Order”), the Director of the Office of Foreign Assets Control has determined, in consultation with the Department of State, that the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation are political subdivisions, agencies, or instrumentalities of the Government of the Russian Federation, …

ROBERT T. BROCKMAN Tax Case
type: item
creator: Michael Nelson
date: 2023-05-23T14:23:28Z
subject: FinCEN
subject: Tax Cases
subject: Tax Compliance
description: See Case here UNITED STATES OF AMERICA, CASE NO. 3:20-cr-00371 WHA Plaintiff, VIOLATIONS: 18 U.S.C. § 371 – Conspiracy to Defraud the United v. States and Commit Tax Evasion; ROBERT...
encoded: See Case here UNITED STATES OF AMERICA, CASE NO. 3:20-cr-00371 WHA Plaintiff, VIOLATIONS: 18 U.S.C. § 371 – Conspiracy to Defraud the United v. States and Commit Tax Evasion; ROBERT T. BROCKMAN

New Hampshire Man Pleads Guilty To Filing False Tax Return
type: item
creator: Michael Nelson
date: 2023-05-23T13:47:21Z
subject: Asset Protection Planning
subject: Featured Articles
subject: FinCEN
subject: Tax Cases
subject: Tax Compliance
description: New Hampshire Man Pleads Guilty To Filing False Tax Return Monday, October 20, 2014 For Immediate Release U.S. Attorney’s Office, District of New Hampshire WASHINGTON – A Hampton, New Hampshire, man...
encoded: New Hampshire Man Pleads Guilty To Filing False Tax Return Monday, October 20, 2014 For Immediate Release U.S. Attorney’s Office, District of New Hampshire WASHINGTON – A Hampton, New Hampshire, man pleaded guilty today in the U.S. District Court for the District of New Hampshire to filing a false federal income tax return for tax year 2009, the Justice Department and Internal Revenue Service (IRS) announced. According to court documents, Menashe Cohen, an oriental carpet dealer, and his sister maintained an undeclared bank account at UBS in Switzerland that had a balance of approximately $1.3 million. Cohen also maintained bank accounts in Israel and in Jersey, a British Crown dependency located in the Channel Islands off the coast of Normandy, France. Although Cohen’s return for tax year 2009 reported that he had a financial interest in a bank account in Jersey, the return failed to report that he had financial interests in the accounts located in Switzerland and Israel. In addition, Cohen’s return only reported $350 in interest income, when in fact he had received approximately $66,500 in interest income during 2009. In total, for tax years 2006 through 2009, Cohen failed to report approximately $170,000 in income earned from offshore bank accounts. In addition, Cohen filed a false and fraudulent Report of Foreign Bank and Financial Accounts (FBAR) for 2009, wherein Cohen reported he had bank accounts in Israel and Jersey on the FBAR, but failed to report his financial interest in the UBS account in Switzerland. According to the law, U.S. citizens and residents who have an interest in, or signature or other authority over, a financial account in a foreign country with assets in excess of $10,000 are required to disclose the existence of such account on Schedule B, Part III, of their individual income tax returns (Forms 1040). Additionally, U.S. citizens and residents must file a FBAR with the U.S. Treasury disclosing any financial account in a foreign country wit…

Former Florida Resident Indicted for Tax Evasion and Failing to Report Foreign Bank Accounts
type: item
creator: Michael Nelson
date: 2023-05-23T13:45:16Z
subject: Asset Protection Planning
subject: Featured Articles
subject: FinCEN
subject: Tax Cases
subject: Tax Compliance
description: FOR IMMEDIATE RELEASE Wednesday, February 10, 2021 Former Florida Resident Indicted for Tax Evasion and Failing to Report Foreign Bank Accounts A federal grand jury returned an indictment today charging...
encoded: FOR IMMEDIATE RELEASE Wednesday, February 10, 2021 Former Florida Resident Indicted for Tax Evasion and Failing to Report Foreign Bank Accounts A federal grand jury returned an indictment today charging Lucia Andrea Gatta, a former resident of Palm Beach County, Florida, with tax evasion and failing to file Reports of Foreign Bank and Financial Accounts (FBARs), among other offenses, announced Acting Deputy Assistant Attorney General Stuart M. Goldberg of the Justice Department’s Tax Division and U.S. Attorney Ariana Fajardo Orshan for the Southern District of Florida. According to the indictment, Gatta was born in Chile and became a naturalized U.S. Citizen in 2012. The indictment alleges that, for calendar years 2012 through 2014, Gatta failed to disclose her interest in a Swiss bank account on annual FBARs as required by law. Gatta also allegedly evaded assessment of income taxes on the interest and dividend income she earned in her Swiss bank account and failed to file tax returns with the IRS for tax years 2011 through 2014. The indictment also charges Gatta with naturalization fraud. According to the indictment, Gatta did not disclose to the Department of Homeland Security’s U.S. Citizenship and Immigration Services (USCIS) that she had failed to report foreign dividend and interest income during her citizenship application process, and she allegedly presented misleading documents to USCIS to substantiate the false statements she made during her naturalization interview. If convicted, Gatta faces a maximum sentence of five years in prison for each count relating to her failure to file an FBAR and tax evasion. She also faces a maximum sentence of one year in prison for each of the counts concerning the failure to file tax returns. If convicted of naturalization fraud, Gatta faces a maximum sentence of ten years in prison and automatic denaturalization. An indictment is an accusation. A defendant is presumed innocent unless and until proven guilty beyond a reaso…

Los Angeles Man Pleads Guilty to Not Reporting over $1 Million Held in Israeli Offshore Accounts
type: item
creator: Michael Nelson
date: 2023-05-23T13:42:43Z
subject: Asset Protection Planning
subject: Banking
subject: Featured Articles
subject: FinCEN
subject: Tax Cases
subject: Tax Compliance
description: Los Angeles Man Pleads Guilty to Not Reporting over $1 Million Held in Israeli Offshore Accounts Monday, August 20, 2018 For Immediate Release U.S. Attorney’s Office, Central District of California...
encoded: Los Angeles Man Pleads Guilty to Not Reporting over $1 Million Held in Israeli Offshore Accounts Monday, August 20, 2018 For Immediate Release U.S. Attorney’s Office, Central District of California LOS ANGELES – A Los Angeles man pleaded guilty today in U.S. District Court to willfully failing to file a Report of Foreign Bank and Financial Accounts (FBAR), which would have disclosed his foreign bank accounts, announced Principal Deputy Assistant Attorney General Richard E. Zuckerman of the Justice Department’s Tax Division. According to court documents, Ben Zion Birman held offshore accounts in Israel at Bank Leumi Le-Israel B.M. from 2006 to 2011. Birman willfully failed to file with the Department of Treasury an FBAR for calendar year 2010, despite having over $1 million in Bank Leumi accounts. In an effort to further hide his money, Birman instructed Bank Leumi to hold bank mail from delivery to the United States, and obtained access to his offshore funds through the use of “back-to-back” loans, which were designed to enable borrowers to tap their concealed accounts. These lending arrangements permitted Birman to have funds issued by Leumi’s U.S. branch that were secretly secured by funds in his undeclared accounts in Israel. In December 2014, Bank Leumi entered into a <a href="http://links.govdelivery.com/track?type=click&enid=ZWFzPTEmbWFpbGluZ2lkPTIwMTgwODIwLjkzODY3NTExJm1lc3NhZ2VpZD1NREItUFJELUJVTC0yMDE4MDgyMC45Mzg2NzUxMSZkYXRhYmFzZWlkPTEwMDEmc2VyaWFsPTE3MzY3NTczJmVtYWlsaWQ9dGhvbS5tcm96ZWtAdXNkb2ouZ292JnVzZXJpZD10aG9tLm1yb3pla0B1c2Rvai5nb3YmZmw9JmV4dHJhPU11bHRpdmFyaWF0ZUlkPSYmJg==&&&101&&&https://www.justice.gov/opa/pr/bank-leumi-admits-assisting-us-taxpayers-hiding-assets-offshore-bank-accounts?utm_medium=email&utm_source=govdelivery">deferred prosecution agreement after the bank admitted to conspiring from at least 2000 until early 2011 to aid and assist U.S. taxpayers to prepare and present false tax returns by hiding income and assets in offshore bank acco…

Azizur Rahman Indictment FBAR case
type: item
creator: Michael Nelson
date: 2023-05-23T13:40:56Z
subject: Asset Protection Planning
subject: Citizenship
subject: Featured Articles
subject: FinCEN
subject: Tax Cases
subject: Tax Compliance
description: ALEXANDRIA, Va. – A federal grand jury returned an indictment today charging a Herndon man with failing to file Reports of Foreign Bank and Financial Accounts (FBARs) and filing false...
encoded: ALEXANDRIA, Va. – A federal grand jury returned an indictment today charging a Herndon man with failing to file Reports of Foreign Bank and Financial Accounts (FBARs) and filing false documents with the IRS. According to the indictment, Azizur Rahman, 70, had a financial interest in and signature authority over more than 20 foreign financial accounts, including accounts held in Switzerland, the United Kingdom, the Republic of Singapore, and Bangladesh. For the years 2010 through 2016, Rahman allegedly did not disclose his interest in all of his financial accounts on annual FBARs, as required by law. Rahman also allegedly filed false individual tax returns for the tax years 2010 through 2016 that did not report to the IRS all of his foreign bank accounts and income. Rahman is also charged with filing a false “Streamlined Submission” in conjunction with the IRS Streamlined Domestic Offshore Procedures. Those procedures allowed eligible taxpayers residing within the United States, who failed to report gross income from foreign financial accounts on prior tax returns, failed to pay taxes on that gross income, or who failed to submit an FBAR disclosing foreign financial accounts, to voluntarily disclose their conduct to the IRS and to pay a reduced penalty if their conduct was non-willful. The indictment alleges that Rahman’s Streamlined Submission did not truthfully disclose all the foreign bank accounts in which he had an interest, and falsely claimed that his failure to report all income, pay all tax, and submit all required information returns, such as FBARs, was non-willful. If convicted, Rahman faces a maximum sentence of three years in prison for each of the counts related to filing false tax documents. Rahman also faces a maximum sentence of five years in prison for each count relating to his failure to file an FBAR or filing a false FBAR. Actual sentences for federal crimes are typically less than the maximum penalties. A federal district court judge will determ…

A professor and researcher at Massachusetts Institute of Technology (MIT)
type: item
creator: Michael Nelson
date: 2023-05-23T13:02:07Z
subject: Asset Protection Planning
subject: China
subject: FinCEN
subject: Tax Cases
subject: Tax Compliance
description: The defendant allegedly failed to disclose his work for the People’s Republic of China to the U.S. Department of Energy BOSTON – A professor and researcher at Massachusetts Institute of...
encoded: The defendant allegedly failed to disclose his work for the People’s Republic of China to the U.S. Department of Energy BOSTON – A professor and researcher at Massachusetts Institute of Technology (MIT) was charged and arrested today in connection with failing to disclose contracts, appointments, and awards from various entities in the People’s Republic of China (PRC) to the U.S. Department of Energy. Gang Chen, 56, was charged with a criminal complaint of wire fraud, failing to file a foreign bank account report (FBAR), and making a false statement in a tax return. Chen will make an initial appearance today before Magistrate Judge Donald L. Cabell. According to charging documents, Chen is a naturalized U.S. citizen who was born in China. He is a professor and researcher at MIT where he serves as Director of the MIT Pappalardo Micro/Nano Engineering Laboratory and Director of the Solid-State Solar Thermal Energy Conversion Center (S3TEC). Since approximately 2013, Chen’s research at MIT has been funded by more than $19 million in grants awarded by various U.S. federal agencies. Since 2012, Chen has allegedly held various appointments with the PRC designed to promote the PRC’s technological and scientific development by providing advice and expertise – sometimes directly to PRC government officials – and often in exchange for financial compensation. This includes acting as an “overseas expert” for the PRC government at the request of the PRC Consulate Office in New York and serving as a member of at least two PRC Talent Programs. Since 2013, Chen allegedly received approximately $29 million of foreign funding, including $19 million from the PRC’s Southern University of Science and Technology (SUSTech). It is further alleged that Chen’s efforts to promote the PRC’s scientific and economic development were partially detailed in a February 2016 email that Chen sent himself using his MIT e-mail account. The email read: promote Chinese collaboration China places innovatio…