US Man Living In Shanghai Owes $2.3M In FBAR After Dropping Out of His OVDP

According to Law360, an American living in Shanghai owes the Internal Revenue Service $2.3 million after failing to report at least a dozen foreign bank accounts on his 2010 tax forms, the U.S. government told a federal court in a complaint in U.S. v. William A. Chen, case number 1:22-cv-03562, in the U.S. District Court for the District of Columbia.

William A. Chen opened the bank accounts in China during 2005 when he planned to relocate from the U.S., the government said in a complaint filed Nov. 22. He failed to disclose their existence and any interest earned on them, according to the government.

Chen opened the accounts at HSBC, Standard Chartered Bank, Deutsche Bank, Industrial and Commercial Bank of China, Shanghai Pudong Development Bank, Morgan Stanley and Bank of China, the government said in its complaint. He moved to Shanghai in 2006 and currently lives in the city, according to the government.

Chen hired PwC to prepare his 2006 and 2007 tax forms but had checked "no" on Form 1040's Schedule B question asking if he had any foreign accounts, according to the government.

Chen began filing Report of Foreign Bank and Financial Accounts in 2008, the government said, but did not fully disclose his accounts in 2008 or in 2010, the U.S. said. The 2010 failure involved 12 foreign accounts held with HSBC, Standard Chartered Bank and Deutsche Bank, the government said. The aggregate highest balance of the accounts totaled $5.7 million, according to the government.

Chen entered the 2014 Offshore Voluntary Disclosure Program in 2015 but dropped out in 2018. The penalties and interest against him total $2.3 million, the government said.

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