Tax Evasion Not Cured with QI Pacts

Criminal Tax Prosecutions, Expat Taxes, News

Published on

March 23, 2014
The IRS U.S. Court building in Washington DC, a courthouse where cases on the Trust Fund Recover Penalty (TFRP) are held

Tax Evasion under QI agreements

The IRS U.S. Court building in Washington DC, a courthouse where cases on the Trust Fund Recover Penalty (TFRP) are held

On Feb. 28 2014, Thomas Sawyer, senior counsel on international tax matters with the DOJ’s Tax Division, clarified that banks who have helped clients hide assets from the US government aren’t immune from penalty simply because they have complied with a qualified intermediary (“QI”) agreement.

Mistaken Beliefs

Sawyer addressed the misconception of some banks that may have decided not to come forward under the mistaken belief that their QI agreements will protect them from enforcement. “If you’re hearing that advice, you should be put on notice that that’s wrong,” Sawyer said. Another misconception is that all banks have to do is pay a fine and they can simply move forward, he said.

An official from the IRS also said that the IRS has attaches in multiple countries to assist with investigations, and is looking at whether taxpayers who renounce their citizenship may be doing so for tax evasion purposes.  Since the enactment of the Foreign Account Tax Compliance Act (“FATCA”), the government has seen an increase in these renunciations. It is very clear that the U.S. Government is committed to combating tax evasion. Foreign Financial Institutions holding U.S. Citizens bank accounts have to either comply with IRS under FATCA or face penalties or to the worst case, close the bank accounts.

Sooner or later, the government will catch up with non-compliant banks and non-compliant U.S. Citizens in foreign countries. There is no option to tax evasion.

Author

Anthony N. Verni

ATTORNEY AT LAW, J.D., CPA, MBA
With 20+ years of experience practicing before the IRS, I bring a rare combination of legal and financial expertise as both an Attorney and a Certified Public Accountant.
Contact Me

Why Trust Us

At Verni Tax Law, we adhere to a stringent editorial policy emphasizing factual accuracy, impartiality and relevance. Our content, curated by experienced industry professionals. A team of experienced editors reviews this content to ensure it meets the highest standards in reporting and publishing.

More Similar Posts

Loading posts...

Lorem Ipsum is simply dummy text of the printing and typesetting industry.

Table of contents

Hear from relieved
Taxpayers who trusted Verni Tax Law Around the World

Anthony was creative in helping me resolve some past issues in a way that they never became a problem so that is greatly appreciated and I feel confident I can now enjoy my retirement with peace of mind. Thanks for that.

Ken B.

Cebu City, Philippines

I came to Anthony Verni with FBAR issues. I was not sure what to expect and felt that I was going to be put in a difficult position financially as well as legally. My fears were unfounded and I was very satisfied with his professionalism and the outcome of my case.

Douglas R.

Osaka, Japan
Load more

Anthony’s help with Swift & Secure Systems Inc., CheckWare Workstations LLC and my personal taxes have been of great value. Since moving to Florida (and my Connecticut Accountant retiring) I have tried various other methods of keeping the accounting and taxes under control.

Phil Y

President, Swift & Secure Systems Inc., Boynton Beach, FL

I would like to thank Anthony N. Verni.   Mr. Verni has successfully represented us before the Internal Revenue Service. We had foreign bank accounts that we inadvertently didn’t report and we were subject to steep penalties. As a result his efforts, the FBAR penalties were waived by the IRS.
Thank You

Yassin and Eva, B.

Farmington Hills, Michigan

EXPAT solution for delayed US tax / FBAR issues
Anthony Verni helped us to file our delayed IRS tax returns and FBAR issues in a very professional way. We are very thankful for his help and guidance thru this nightmare of rules and are highly recommending his service.

Andrea

IRS FBAR and OVDI compliance representation expertise
As a long-term ex-pat US citizen living in Europe, I was surprised several years ago by an polite invitation from the IRS, via email, to consider filing FBARs, along with updated income tax returns. Although (or because) I am a university academic with specialization in comparative labor law, I quick…

Charles

Sound advice. High caliber work.

One of those people who were born by chance in the USA but never lived or worked there, in 2015 , I had no choice but to file returns with the IRS. For this purpose, fortunately, I found Mr Verni on the internet and entrusted him with the complex process involved in using the Streamlined Foreign Offs..Read more

Carlos

EXPAT solution for delayed US tax / FBAR issues

Anthony Verni helped us to file our delayed IRS tax returns and FBAR issues in a very professional way. We are very thankful for his help and guidance thru this nightmare of rules and are highly recommending his service.

Andrea

Verni’s professional services Review

Beside his inbepth knowledge of the law, Anthony will setup weekend appointments to accommodate his clients. I really appreciate that because otherwise I would have had to miss time, thus money from work.

Elder

Excellent service

Mr. Verni provided excellent service for my tax law matter and also income tax preparation. Highly recommended.

anonymous

Tax issues

Anthony Verni helped us resolve our tax issues. He guided us through the whole process and took care of the filings. He is extremely courteous and reassuring. He also explains the options available and advises what he thinks you should do.

anonymous

President
I have known and have had the pleasure of having Anthony Verni representing me on several projects over the last 20 years. I have always found him to be conscientious and diligent in working within my time restraints and goals. He has been dedicated and responsive in providing me with the the legal r..Read more

Frank Pirol

Offshore voluntary disclosure issues

Mr. Anthony Verni, your expertise and professionalism in handling my offshore voluntary disclosure case far exceeded my expectations. Thank you and appreciate for providing guidance, support and presenting the facts of my case. I simply could not have been more pleased with the process and outcome. ..Read more

Vikram Patel

The expat’s solution to US tax problems

I met Anthony after comparing advice and quotes from 5 different expat tax experts, all based in the U.S. I had an initial free telephone consult with Anthony about my issues with non-filing of Fbars for my foreign accounts investments. The other attorneys I contacted had advised me that the onl..Read more

Brian

Have questions or need guidance?

I’m always available by phone, email, or Skype whatever’s easiest for you.

Take the first step and let me help fix the root of your tax problems.