The U.S. government is moving forward in its lawsuit against a U.S. taxpayer accused of a willful failure to disclose offshore bank accounts. In Washington State district court, a judge denied the taxpayer, Jeffrey P. Pomerantz’s, motion to dismiss the case, instead ruling that the government had provided sufficient factual evidence to support a “reasonable inference” that Mr. Pomerantz was liable of a willful failure to report accounts he controlled in Canada and Switzerland during tax years 2007, 2008 & 2009.
Increasingly, the U.S. government has signaled a willingness to bring forward both significant civil and criminal cases against taxpayers alleged to have unreported foreign accounts. In the case of Mr. Pomerantz, the Department of Justice is seeking to collect around $860,000 in civil penalties assessed for his years of failing to file a Report of Foreign Bank and Financial Accounts (FBARs). Taxpayers with years of unreported offshore accounts may be at risk and should contact the experienced tax attorneys at Rosefelt & Associates to discuss their legal options, including the IRS Offshore Voluntary Disclosure Program (OVDP).