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In Shore v. U.S., a retired man opened a farm equipment business on his property with a managing partner. At the time the business was opened, the man verbally agreed to let the managing partner buy his interest in the business at any point in the future as long as the partner paid the man the $150,000 that he initially invested.

Each year, United States citizens and permanent residents are required by law to report all of their income to the Internal Revenue Service, no matter where it was derived. Under the tax code, any individual with an ownership or signature authority over a foreign bank account or other offshore financial asset with an aggregate value of at least $10,000 during the tax year is required to file a Report of Foreign Bank and Financial Accounts (“FBAR”). An American taxpayer who fails to timely file the FBAR faces potential fines as well as criminal prosecution.


A Jamestown, Kentucky man was recently arrested and charged with tax evasion and conspiring to defraud the United States government by using secret foreign bank accounts to hide assets. According to a press release issued by the U.S. Attorney’s Office for the Southern District of New York, the man stands accused of establishing and maintaining several secret financial accounts in Switzerland using a sham foundation so that he could avoid paying his U.S. tax liability. He will reportedly be arraigned in a Manhattan federal court in early December.


In Ransier v. U.S., a woman filed a lawsuit in federal court seeking to recover $3,600 in trust fund recovery penalties that were withheld from the woman’s 2011 federal income tax refund by the U.S. government. The plaintiff also asked the court to rule that she was not a responsible person under 26 U.S.C.

The District of New Jersey has ordered a couple to comply with an Internal Revenue Service summons to produce documents related to undisclosed foreign financial accounts. In U.S. v. Chabot, the IRS apparently received information from a French authority suggesting the owner of a business failed to disclose offshore bank accounts that were held in the company’s name between 2005 and 2007.

According to a recent survey, nearly three-fourths of the 7.6 million United States citizens who live overseas are now considering handing in their passports. Many Americans who are thinking about renouncing their citizenship are reportedly concerned about complying with the 2010 Foreign Account Tax Compliance Act (“FATCA”). The law went into effect on July 1, 2014 and requires foreign banks to disclose financial information about U.S. citizens who maintain assets valued at more than $50,000 overseas. Banking institutions that fail to comply with FATCA face possible exclusion from U.S.

According to the United States Justice Department, a New Hampshire businessman recently pleaded guilty to filing a false and fraudulent federal income tax return for the 2009 tax year. The man apparently jointly held a secret offshore bank account in Switzerland with his sister. The high balance of that unreported overseas financial account purportedly reached about $1.3 million in 2009. In addition, the businessman reportedly failed to report his interest in a financial account with an Israeli banking institution on his income tax return.


A Los Angeles businessman has pleaded guilty to conspiracy to defraud the United States government. According to the U.S. Justice Department, the American citizen owned a number of Israeli bank accounts that he failed to report to the Internal Revenue Service. The L.A. man apparently held the accounts in the names of nominee corporate entities in an effort to avoid detection by the agency. In addition, he purportedly asked the Israeli financial institution where the accounts were opened to hold his mail.

In U.S. v. Kraft, a New Jersey couple was assessed a combined trust fund recovery penalty of more than $430,000 in 2001. Federal law states that employers in the U.S. are required to withhold social security, Medicare, and certain other taxes from each worker’s paycheck.

A certified fraud examiner and forensic accountant has reportedly pleaded guilty to willfully hiding almost $1 million from the Internal Revenue Service in a Swiss bank account. In USA v. Bloomberg, a 55-year-old Atlanta man was accused of failing to report his ownership and control interest in a foreign bank account between 1997 and 2008. According to the United States Justice Department, the Georgia man failed to report an account that was held at UBS AG, one of the largest banks in Switzerland.