tag:blogger.com,1999:blog-1519969502186924526.post2339678164779460296..comments2023-10-24T08:00:53.865-05:00Comments on Federal Tax Crimes: IRS Extends FBAR / Foreign Entity Relief Deadline to 10/15/09Jack Townsendhttp://www.blogger.com/profile/14469823736335455874noreply@blogger.comBlogger3125tag:blogger.com,1999:blog-1519969502186924526.post-30490543456206686102009-10-12T08:16:25.617-05:002009-10-12T08:16:25.617-05:00Anonymous,
Thanks for your comment. I think it w...Anonymous,<br /><br />Thanks for your comment. I think it would be a stretch. But, I do believe there is some basic unfairness to closing voluntary disclosure to those in the first wave but opennng voluntary disclosure to those in the second (and perhaps later) waves.<br /><br />Jack TownsendJack Townsendhttps://www.blogger.com/profile/14469823736335455874noreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-23105712730224387922009-10-02T08:36:03.389-05:002009-10-02T08:36:03.389-05:00Do you think there are any due process issues asso...Do you think there are any due process issues associated with the fact that the second group of UBS names has gotten 1) advance warning from UBS, 2) simplified disclosure process, 2) more time the first group of UBS names and 4) even an extension of time? It would seem that one group of people is being treated differently than the second group. Actually, that raises another question...because the selection of who is in what group was made by a confessed criminal party - UBS. Do you think there are due process issues and issues with the UBS' role in determining who made which list?Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-26299079047758512632009-09-30T14:28:37.845-05:002009-09-30T14:28:37.845-05:00Do you think that extending the deadline and UBS r...Do you think that extending the deadline and UBS recently notifying their 3,000 clients of their filing obligations will create any due process issues for the government since the first set of names turned over in February did not have the same early warning to become compliant ahead of a deadline? And what about the fact that the selection of the first group of names was made by UBS not exactly a neutral party....potential due process issue or not?Anonymousnoreply@blogger.com