FBAR Enforcement and Litigation: Recent Cases, Penalties, Willful and Non-Willful Violations, Practical Implications

Mr. Drabkin is a Certified Tax Law Specialist by the State Bar of California. He devotes his skills and experience to representation of clients who are in disputes, or have compliance issues, with the Internal Revenue Service and State taxing authorities, both administratively and in court. Mr. Drabkin litigates cases in all federal and state courts, including U.S. Tax Court, U.S. District Court, Court of Federal Claims and U.S. Bankruptcy Court. In addition, he represents clients in tax audits, fraud and criminal investigations, administrative appeals, tax collection and bankruptcy matters. Mr. Drabkin also has extensive experience representing clients with offshore tax compliance issues, including Offshore Voluntary Disclosure, FBAR audits and Grand Jury investigations related to foreign bank accounts.

Mr. Patel’s practice concentrates on tax, international tax planning, estate planning, and elder law. His focus is on all tax matters including international tax law, foreign bank account disclosures, tax audit defense, and tax appeals. He has advocated over one hundred voluntary tax disclosures for assets before the US Internal Revenue Service. Mr. Patel is a frequent speaker and writer on legal issues affecting tax, foreign account planning, and estate planning. He is a New Jersey Super Lawyer by New Jersey Magazine for tax and estate planning. Mr. Patel has also received an AV rating from the Martindale-Hubbell Peer Review Rating System, which is the highest professional rating possible among lawyers. He is the Chairman of the Tax Law Committee of American Bar Association’s GP Solo and Small Firm Division. Mr. Patel is a member of the New Jersey State, New York State, Florida, and American Bar Associations. He also serves as Municipal Court Judge for Westfield Township and Edison Township Municipal Courts, with jurisdiction of vehicular violations, temporary restraining orders, criminal and ordinance offenses.

Mr. Verni is a Tax Attorney and Certified Public Accountant with over 20years’ experience practicing before the Internal Revenue Service. His practice is focused on representing Expatriate and other U.S Taxpayers who have criminal and civil tax issues related to offshore tax evasion, money laundering, failure to file income tax returns, failure to report offshore income, failure to file FBAR reports and other tax related compliance and reporting concerns. Mr. Verni also represents individuals and businesses in connection with tax controversies involving income, estate and gift and employment taxes.