1. As the title suggests, tax schemes are proliferating. Some of the tax schemes are variations on historic scams. In any event, there should be continuing business for persons practicing in the tax crimes area.
2. On the IRS Voluntary Disclosure front, the following is, in my mind, the key observation:
On average, those who took advantage of the amnesty will lose roughly 50 to 60 percent of the amount in an ordinary deposit account, that is, one without significant earnings, and a higher percentage if the account was an investment account. The amnesty offered a great deal to the traditional tax cheat, said Charles Rettig of Hochman, Salkin, Rettig, Toscher & Perez, but those who missed the October 15 deadline might still want to use the regular voluntary disclosure program to avoid potential criminal prosecution. (For the IRS amnesty instruction, see Doc 2009-14388 [PDF] or 2009 TNT 120-8 .)3. And, on Voluntary Disclosure:
Matthews marveled at the vast sums that people were willing to park in bank accounts with no paper evidence that they owned the money, and often paper saying that some nominee owned it. He wondered whether these people would be as trusting of other tax havens now that they had been chased out of Switzerland.I could say more on this, but my readers would think I am just piling on the Swiss banks (not that any thing I would say would materially increase the pile).
4. More important for tax procedure than tax crimes, the historic division of representation in the various forums for civil litigation is blurring. Ms. Sheppard report: "And taxpayer selection of forum does not mean one set of lawyers: IRS lawyers and Justice lawyers are working together in all courts."