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White Paper

Criminal Tax Issues- IRS and Off-Shore Tax Evasion and Waiver of Civil and Criminal Penalties

 

“Please review the following client criminal tax issues:

1) Your duty as a tax practitioner Treas. Dept Circular 230 (Sec. 10.21): your knowledge of client's non-compliance with US revenue laws, or omissions/ errors on tax returns requires you advise client promptly of fact of client's non- compliance or error and consequences;

2) Failures to file Form 3520 subject client to 35% penalty re: distributions received;”

“U.S. Taxpayers who commit offshore tax evasion are subject to serious civil and criminal penalties, which may include:

1. An FBAR civil penalty of up to 150% of the account balance (see: 5/14 case of Florida Taxpayer Carl Zwerner)
2. 20%-40% accuracy related penalty (on underpayment of tax due).
3. Civil Tax Fraud penalty (75% of tax due) and suspension of the IRS statute of limitations for civil tax audits

Criminal Penalties
Criminal Prosecution for Tax Crimes: Willful Evasion of Tax (5 years in jail; IRC 7201), Obstruction of Tax Collection (3 years in jail; IRC 7212), Conspiracy to Commit Tax Evasion (5 years in jail; 18 USC 371), Filing a False Tax Return (3 years in jail; IRC 7206), Failure to File FBAR ( 10 years in jail for each tax year not filed; Fincen form 114) .”

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Our author, Gary S. Wolfe, has more than 34 years of experience, specializing in IRS Tax Audits and International Tax Planning/Tax Compliance, and International Asset Protection.

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Criminal Tax Issues- IRS and Off-Shore Tax Evasion and Waiver of Civil and Criminal Penalties

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Criminal Tax Issues- IRS and Off-Shore Tax Evasion and Waiver of Civil and Criminal Penalties

Faculty

Gary S. Wolfe

The Wolfe Law Group

Our author, Gary S. Wolfe, has more than 34 years of experience, specializing in IRS Tax Audits and International Tax Planning/Tax Compliance, and International Asset Protection.

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In Partnership With

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Criminal Tax Issues- IRS and Off-Shore Tax Evasion and Waiver of Civil and Criminal Penalties

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