U.S. Taxpayer Pleads to FBAR and Tax Perjury Violation (3/14/13)

In a Bloomberg article that I just posted, there is a discussion of an FBAR plea agreement which I had not been aware of before.  David Voreacos & Patricia Hurtado, U.S. Tax Cheats Nailed After Swiss Adviser Mails It In (Bloomberg 3/13/13), here.  According to the Article, Michael Canale pled guity to an FBAR Violation and a Tax Perjury.  The plea occurred in December and sentencing is schedule next month.  The pertinent parts of the article are:

Both Thomann [another Swiss Banker/Enabler[ and Singenberger helped Canale, the retired Army surgeon, according to Canale’s charging document, known as a criminal information. 

Thomann had handled the account of a relative who died in 2000, leaving the money to Canale. Thomann introduced Canale to Singenberger to set up a structure that “would, to the greatest extent possible, obscure from the IRS” his ownership of his undeclared account, according to the information. 

Singenberger set up a Liechtenstein foundation for Canale, and helped him open an account at Wegelin, prosecutors said. By 2009, the account had grown to $1.5 million. 

Bronze Star 

Canale, 62, is a Bronze Star recipient who worked for the Army as a field surgeon during Desert Storm in Saudi Arabia, Iraq and Kuwait, according to one of his lawyers, Martin Press. He also was a surgeon in Macedonia and Kosovo, Press said. 

* * * * 

Canale, who was also a paratrooper, worked for the Veteran’s Administration from 2010 until retiring last year, Press said.

“It’s very sad,” said Fink. “It was an account that he inherited. He never wanted to do anything with it. It’s the most sympathetic case I’ve ever seen. It’s a disaster based on a misfortune that he did not deserve. If anyone deserve leniency, he does.” 

Canale pleaded guilty to failing to declare his account on tax returns, and failing to file a Report of Foreign Bank and Financial Accounts with the Treasury Department. He will be sentenced in federal court in New York next month, Press said.

I will post more information on the plea when I receive it.  I will post a new blog on the sentencing when I receive that information.