|"Tipping the scales of justice in
|Defending and protecting businesses and financial professionals from IRS audits, Insurance
companies and Brokerage firms.
|Our Professional Services >>
- FBAR undisclosed foreign
asset reporting (IRS)
- Offshore Voluntary
- Research & Analysis of
- Providing Guidance for
CPAs & Insurance
- Stock market, Mutual fund
& Insurance loss recovery
- Life Settlement Lawsuits
- Premium Financing
- Retirement Plan Lawsuits
- Employee benefit plan
- IRS Audit assistance
- Plan reviews, evaluations
- Expert Witness testimony
Servicing Individuals and
|A few of our recent successful resolutions for
|"Our expert witness, Lance Wallach has never lost a case!"
Jail time for failure to file TD F 90-22.1 Report of Foreign Bank and
A former UBS, AG ("UBS") client from Miami Beach, Florida was sentenced to four months in federal
prison for willfully failing to file a Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts
("FBAR"), for the UBS account the man held with as much as $4,000,0000 in it. This information was
released by the U.S. Attorney for the Southern District of Florida on July 25 2012.
The former UBS client paid a civil penalty of $2,000,000 related to the $4,000,000 high account balance
stemming from tax year 2006. Additionally, the former UBS client was sentenced to four months in
federal prison, three years of supervised release, 250 hours of community service and a $20,000
The UBS account related to two offshore corporations owned by the man, one in the Virgin Islands
and one in the Republic of Panama. These corporations opened accounts at UBS. The man was not
named as the direct owner but instead he was deemed only the "beneficial owner." The accounts with
UBS were opened from tax years 2005 through 2007.
It is stated that the man was aware of the obligation on the FBAR to report as he had previously filed
FBARs for other offshore corporations. An FBAR is required to be filed by both U.S. citizens and
residents who have a financial interest in or signatory authority over a non-U.S. financial account with
a value of more than $10,000 at any point during the tax year. The $10,000 amount is an aggregation of
all non-U.S. financial accounts and not just an analysis on an account-by-account basis.
The information on the former UBS client was turned over after UBS agreed in February 2009 to pay
$780,000,000 under a deferred prosecution agreement to settle the claim that UBS conspired to
defraud the U.S. by impeding the Internal Revenue Service ("IRS"). UBS also agreed to turn over
information to the U.S. Department of Justice on 300 account holders. Google Lance Wallach for more
articles on point.
A US citizen or resident that held an account with UBS or any other institution that has not filed the
necessary FBARs for the last eight tax years, should immediately reach out to get help to discuss any
potential issues they may have and their alternatives. Filing for amnesty and then opting out are two
options that our former IRS agents have successfully done for our clients. If not done properly it can
be a disaster. We suggest you use a CPA with years of prior experience with the IRS international
Lance Wallach, National Society of Accountants Speaker of the Year and member of the AICPA faculty
of teaching professionals, is a frequent speaker on FBAR, OVDI, IRS tax amnesty and opting-out
abusive tax shelters, international tax, and estate planning. He writes about 412(i), 419, Section79,
FBAR, OVDI, IRS tax amnesty and opting-out and captive insurance plans. He speaks at more than ten
conventions annually, writes for over fifty publications, is quoted regularly in the press and has been
featured on television and radio financial talk shows including NBC, National Public Radio’s All Things
Considered, and others. Lance has written numerous books including Protecting Clients from Fraud,
Incompetence and Scams published by John Wiley and Sons, Bisk Education’s CPA’s Guide to Life
Insurance and Federal Estate and Gift Taxation, as well as the AICPA best-selling books, including
Avoiding Circular 230 Malpractice Traps and Common Abusive Small Business Hot Spots. He does
expert witness testimony and has never lost a case. Contact him at 516.938.5007, wallachinc@gmail.
com or firstname.lastname@example.org visit www.taxadvisorexperts.com or www.Lawyer4Audits.com.
The information provided herein is not intended as legal, accounting, financial or any type of advice
for any specific individual or other entity. You should contact an appropriate professional for any
Abusive Offshore Tax Avoidance Schemes
Q. I keep hearing about "Foreign Trusts". Is that what this is about?
A. Yes and no. Initially, the need for enhanced "offshore" compliance efforts was determined as a result of
noncompliance observed in numerous trusts. Trusts lend themselves to being the type of entity through which
income and assets are more easily hidden or disguised. Because they are flow-through entities, the facts
behind true ownership of income or assets may be difficult to establish. Secrecy laws found in most tax havens
only compound this difficulty. Many different foreign entities and schemes are being promoted and used by U.
S. taxpayers to evade tax.
The list includes the use of:
• Foreign trusts
• Foreign corporations
• Foreign (Offshore) partnerships, LLCs and LLPs
• International Business Companies
• Offshore private annuities
• Offshore private banks
• Personal investment companies
• Captive insurance companies
• Offshore bank accounts and credit cards
• Related party loans
It is important to note that the list is not all-inclusive. Promoters of such schemes always appear to be
"improving" the products and services that they market. Read More...
The Law Offices of Mark Levinson, Esq.
We will work to recover your
losses from the stock market &
abusive insurance based plans
from the insurance companies,
brokerage firms & banks.
|Our tax resolution offices have
received plans: CJA, CJA and
Gtist Mill,SADI,Nova Trust,Sea
Nine Veba, Benistar,Robin
|The 2012 National Taxpayer
Advocate (NTA) Annual Report to
Congress criticized current IRS
practices in the Offshore Voluntary
Disclosure Program (OVDP) that
hinder voluntary compliance by
penalizing taxpayers who are
entitled to a reasonable cause
exception from willfulness. One of
the major complaints of the 2011
OVDI was that penalty presumed
So not let your advisor learn his job
with your money. Lance Wallachs
team is led by a CPA who was in the
international tax division of the IRS
as a manager. He was also an IRS