TaxProf Blog

Editor: Paul L. Caron, Dean
Pepperdine University School of Law

Sunday, November 6, 2016

University Of Rochester B-School Professor Pays $100 Million FBAR Penalty Over Swiss Accounts

Horsky 2Department of Justice Press Release, Emeritus Professor Pleads Guilty to Conspiring to Defraud the United States and to Submitting False Expatriation Statement; Hid Account Containing $200 Million Also Paying $100 Million Civil FBAR Penalty:

A Rochester, New York emeritus professor of business administration pleaded guilty today to conspiring with others to defraud the United States and to submitting a false expatriation statement to the Internal Revenue Service (IRS), announced Principal Deputy Assistant Attorney General Caroline D. Ciraolo, head of the Justice Department’s Tax Division, and U.S. Attorney Dana J. Boente of the Eastern District of Virginia, after the plea was accepted by U.S. District Judge T.S. Ellis III.

According to documents filed with the court and statements made during the plea hearing, Dan Horsky, 71, is a citizen of the United States, the United Kingdom and Israel and was employed for more than 30 years as a professor of business administration at a university located in New York [University of Rochester].

Beginning in approximately 1995, Horsky began investing in numerous start-up businesses through financial accounts at various offshore banks, including one bank in Zurich, Switzerland. Horsky created “Horsky Holdings,” a nominee entity, to hold some of the investments and he used the Horsky Holdings account, and later, other accounts at the Zurich-based bank, to conceal his financial transactions and financial accounts from the IRS and the U.S. Treasury Department. 

Wall Street Journal, U.S. Professor to Pay $100 Million Tax Penalty Over Swiss Accounts

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How can someone be a "citizen" of three countries? I've heard of dual nationals, but not triple nationals...

Posted by: Andy Patterson | Nov 6, 2016 11:14:03 AM

I know someone with 4 citizenships.

Posted by: LM | Nov 6, 2016 2:30:27 PM

I have to file an FBAR every year, but the amount of money is comparatively negligible. But this is a good reminded to file it nonetheless!

Posted by: anon | Nov 6, 2016 3:53:23 PM

Must be nice to be able to afford a $100 MILLION penalty. Rochester clearly pays well:-)

Posted by: len fuld | Nov 7, 2016 6:08:44 AM

I guess this proves that if you refuse the amnesty and absolutely twist their arm, to do so, the DOJ will prosecute you for hiding income in foreign countries

The statistics from the amnesty program suggest that there are a couple of dozen fat-cats in every state with a lot of money and no excuse whatsoever who ought to be finishing up their terms at the federal work camp about now.

Posted by: Jim Harper | Nov 7, 2016 1:23:04 PM