Pascazi Law Offices has a Special Interest in Asset Protection, Offshore Banking, Offshore Entity Formation, U.S. Reporting Compliance, and Defense of IRS, and U.S. Department of Justice Criminal & Civil Investigations and Prosecutions. It is not illegal per se for a U.S. person (a U.S. citizen, U.S. permanent resident, and others defined by statute) to open and maintain a foreign bank account, a foreign corporation or a foreign trust, including an asset protection trust. There are numerous legitimate reasons for such activities. However, such activities are governed by a myriad of U.S. laws, rules, and regulations. Pascazi Law Offices understands these laws, rules, and regulations, and can help individuals to be sure that he/she begins offshore banking, and offshore entity formation in compliance with U.S. laws, and that its clients stay in compliance. Pascazi Law Offices possesses a great deal of knowledge as to the lawful opportunities available in Switzerland, the Cayman Islands & the Bahamas to name but a few foreign jurisdictions. It is helpful that the Pascazi Law Offices possesses fluency in English, French, and Italian, which happen to be the primary languages used in most offshore jurisdictions. That having been said, for those persons already holding offshore bank or brokerage accounts which may not be in compliance with U.S. law; the Pascazi Law Offices can help them to come into compliance, as quickly, efficiently, and painlessly as possible, under the strictures of U.S. law. Individual taxpayers who file U.S. tax returns, and who have offshore financial accounts must report income from these offshore financial accounts on Schedule B of their IRS Form 1040 income tax returns. They must also declare the existence of these offshore accounts on their U.S. income tax returns. Furthermore, U.S. persons with signatory authority over, or an interest in offshore financial accounts are required to file IRS Form TFD 90-22.1; no later than June 30th of each year. U.S. persons with a foreign financial account including an offshore bank account or an offshore securities account who do not file IRS Form TDF 90-22.1 can be hit with both criminal prosecution, and/or civil prosecution. The criminal punishment upon conviction is a maximum fine of $250,000, or five (5) years in federal prison, or both. See 31 U.S.C. § 5322(a). Even if no criminal punishment is imposed the civil tax penalties are stunningly expensive. For willful violations which took place before October 23, 2004, a penalty up to the greater of the entire balance in the foreign financial account (not to exceed $100,000), or $25,000 may be imposed. Anyone who willfully violates U.S. reporting law after October 22, 2004, can incur a maximum penalty equal to the greater of $100,000, or 50 percent of the entire balance in the foreign financial account. See 31 U.S.C. § 5321(a)(5). It is important to note, however, that these are the maximum penalties, and that the Pascazi Law Offices MAY be able to negotiate a smaller civil fine or lighter criminal sentence. For those persons that are the target of an IRS or U.S. Department of Justice investigation or prosecution; you have rights. Pascazi Law Offices are well prepared to defend those rights, and advance the best defenses possible, while at the same time continuing a dialog with U.S. government officials, with an eye toward an advantageous bargained disposition. For those clients wanting “their day in court” at all costs, as opposed to a “plea bargain”, the Pascazi Law Offices is prepared to give that to them with the best possible defense posture. Ever wonder if those alleged foreign account documents so often waived around by U.S. prosecutors are actually admissible as evidence in a U.S. court of law, without testimony of the Swiss banker, for instance, to authenticate them? Well, the Pascazi Law Offices has done more than wonder, and quite often that purported evidence is not admissible. The Rules of Evidence are important, and they do matter. Pascazi Law Offices will not allow its clients to be “run roughshod” over by those waiving about purported evidence no more probative than a cocktail napkin. Given the charged political and prosecutorial climate surrounding offshore financial accounts these days, those U.S. persons who have been informed by foreign officials, such as the Swiss Federal Tax Authority, that their names are in line to be turned over to the IRS, or those U.S. persons who have been informed by the IRS that they are the target of an investigation, or those U.S. persons who hold now, or who have held offshore accounts would be well served to engage competent legal counsel, such as the Pascazi Law Offices, as soon as possible, to sort out their individual circumstances, and potential liabilities. This is a situation, whereby, doing nothing could cost you a bundle, or worse, could land you at a no frills hotel run by the U.S. Bureau of Prisons! Click here for an article authored by Attorney Pascazi, concerning the current international climate regarding offshore financial accounts, entitled: IRS to Launch Prosecution of Another Foreign Bank for Aiding and Abetting U.S. Tax Fraud Similar to the Case Brought Against UBS. Should you have any questions or concerns about your legal rights, and/or obligations in any legal matter, or transaction, do not hesitate to contact the Pascazi Law Offices for a free initial consultation. Pascazi Law Offices PLLC 1065 Main Street, Ste. D, Fishkill, New York 12524 U.S.A. Ph: +1 845.897.4219 / Fax: +1 845.468.7117* E-mail: Info@pascazilaw.com* *Service Not Accepted by Fax or E-mail 22 Avenue Pierre Köenig, 95200 Sarcelles [Paris] FRANCE** Tél: +33 9.77.21.86.40 **Service Américain Non Accepté Ici We are required by IRS Circular 230 to inform you that any statements contained herein are not intended or written to be used, and cannot be used, by any taxpayer, for the purpose of avoiding any penalties that may be imposed by U.S. Tax Law. The content of this website is not, and is not intended to be, legal advice. Each case is based upon its own unique facts and circumstances which must be addressed on their own merits. Past performance is no guaranty of future success. Copyright 2011 - Pascazi Law Offices PLLC. All Rights Reserved. This site contains trademarks that are the property of their respective owners. Hosted by Yahoo! Site Terms of Use Agreement |
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| ASSET PROTECTION - OFFSHORE ACTIVITIES |
(845) 897-4219
