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Friday, July 31, 2009

Get in Line Brother #15 - U.S. - UBS Settlement Reported

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The newspapers are reporting that the U.S. and UBS have reached some agreement. The Wall Street Journal's article is here . The announce...
Wednesday, July 29, 2009

July 2009 IRS Posting on Offshore Account Voluntary Disclosure (7/29/09)

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The IRS has posted a new page on the voluntary initiative. The main voluntary disclosure web page is here . The new web page is here and is...

Get in Line Brother #14 - Another Plea in UBS

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Another UBS client, one Jeff Chernick , pled guilty. These guilty pleas may become ho-hum after a while, so in the future I will post thes...
1 comment:
Friday, July 24, 2009

Other Players in “Abusive” Tax Shelters

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Most of the public angst over abusive tax shelters have been targeted at the promoter promoters, including the law firms rendering more like...
4 comments:
Friday, July 17, 2009

A Guilty Plea Too Soon!

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I am in the process of reviewing David Rivkin's sentencing memorandum. I will have a subsequent post on Rivkin's memo and the Govern...
1 comment:
Wednesday, July 15, 2009

IRS Guys in the Trenches on the UBS Mess

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My experience -- dated experience, I might add -- with DOJ Tax was that, as attorneys litigating in the federal district court, we relied he...

Incarceration - Making the Best of It

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The Wall Street Journal Law Blog here has an interesting discussion with a prison consultant who advised Bernie Madoff on his life in priso...
2 comments:
Tuesday, July 14, 2009

Get in Line Brother # 13 - Quickly for UBS Account Holders

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The Wall Street Journal has an informative, albeit tentative, article here today on the status of the UBS - U.S. spat over foreign accounts...
Sunday, July 12, 2009

UBS-US Settlement - Internet Buzz

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The internet is buzzing again about a potential settlement in the UBS-US spat about U.S. person identities. See the WSJ article here . I k...
Friday, July 10, 2009

Help from Readers - Quantifying the Evaded Tax (7/10/09)

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I received an inquiry from a reader about a variation of the theme discussed in the Stadtmauer post here . Stadtmauer held that, for sente...

Update on the Daugerdas indictment -- Guilty Plea by Defendant Greisman (BDO)

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Robert S. Greisman, former DBO Seidman former partner, pleads guilty. See the USAO SDNY press release here . The plea is to three counts - (...
1 comment:
Wednesday, July 8, 2009

The UBS-U.S. Spat Over U.S. Taxpayer Information Continues

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I do not use this blog as a daily rag of news events, but this one seems so significant that I am posting it. According to a New York Times ...
Monday, July 6, 2009

Houston Business & Tax Journal Symposium on Tax Evasion and White Collar Crime (7/6/09)

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Houston Business and Tax Journal Volume 9 Part 2 Caveat:  I previously provided links on this page but HB&TJ moved the publications to ...
Tuesday, June 30, 2009

Check the Tax Loss Numbers: A Tale of Ineffective Representation (6/10/09)

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We have a cautionary tale of woe in a recent case, Baxter v. United States (E.D. Ill. 6/25/09), available here . In the opinion, the court ...
Monday, June 29, 2009

Civil Tax Arcana Related to Voluntary Disclosure Program (6/29/09)

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The expanded FAQs published June 23, 2009 has the following Q&A: 31. How can the IRS propose adjustments to tax for a six-year period ...
Sunday, June 28, 2009

Sentencing Memoranda in U.S. v. Madoff

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For good examples of advocacy in the workings of the post- Booker sentencing, including the necessary Sentencing Guidelines calculations, i...
Saturday, June 27, 2009

FBARs required for Offshore Hedge Fund, Equity Fund Investors

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According to this morning's edition of Tax Notes Today, an IRS spokeman yesterday asserted that "the IRS's position is that inv...

FBAR Question - U.S. Parent, Foreign Sub with Foreign Account

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I ask my readers for help on a question of where on the FBAR form for a parent corporation filing the FBAR form to report foreign accounts o...
1 comment: