Pages

▼
Wednesday, November 3, 2010

Another Foreign Bank -- in Israel -- Gets In Line

›
Bank Leumi, Israel's largest bank, "is asking its clients to declare that they are not U.S. persons or reveal their accounts to U.S...
4 comments:
Sunday, October 31, 2010

Government Pursues FBAR Penalty in Civil Case (10/31/10)

›
In United States v. McBride (D. Utah No. 2:09-cv-378-DB-BCW), the Government seeks to enforce civil penalty for failure to file FBARs for 2...
7 comments:

Ninth Circuit Applies Perlman Rule for Collateral Appeal of Order Rejecting Attorney-Client Privilege for Former Attorneys of NonIndicted Party (10/31/10)

›
In United States v. Krane , 625 F.3d 568 (9th Cir. 2010), here , the Ninth Circuit upheld the continuing viability of the Perlman rule perm...
Thursday, October 28, 2010

Other UBS Account Holders are Charged

›
The Boston Globe reports here that two other UBS account holders were charged in separate cases.  The individuals are Peter Schober and Gre...
5 comments:
Friday, October 22, 2010

Developments on the UBS / Swiss Front

›
There is a flurry of news this morning about UBS, probably the most egregious of Swiss banks in the business of enabling U.S. tax cheats: ...
1 comment:
Wednesday, October 20, 2010

Another Tax Shelter Lawyer Bites the Dust

›
Erwin Mayer, a Paul Daugerdas partner and co-defendant in the tax shelter indictment in SD NY, has pled guilty. I have previously blogged o...
Saturday, October 16, 2010

Can Signatories Filing FBARs During the Administratively Extended FBAR Filing Period Be Prosecuted for Failure to File? (10/16/10)

›
Readers will recall that the IRS administratively granted U.S. persons with signatory only authority (i.e., no financial interest) relief pr...
8 comments:

Government Discretion to Charge where Criminal Statutes Overlap (10/16/10)

›
In United States v. Jenkins , 2010 U.S. Dist. LEXIS 106847 (ED VA 2010) , the defendant was charged with tax evasion (§  7201 ). The evasion...
Thursday, October 14, 2010

Update on Fidelity International Advisor Currency Fund A (10/14/10)

›
I previously blogged three times on the Fidelity International Advisor Currency Fund A case. The principal blog is titled " Judge Find...
2 comments:
Tuesday, October 12, 2010

Cheek Good Faith - Must the Defendant Testify to Assert the Good Faith "Defense" (10/13/10)

›
One of the problems with asserting the so-called Cheek good faith “defense” at trial is that, as one court recently held, the defendant wil...
Thursday, October 7, 2010

Practitioners Complain About U.S. Reliance on Thieves Who Steal from Thieves Who Assist U.S. Taxpayers Cheat on Taxes

›
Practitioners are all atwitter about the U.S. obtaining information -- presumably for consideration of some sort -- misappropriated from off...
3 comments:

Sometimes the Guilty are Really Guilty, But Not These If You Believe Their Lawyer (Whom the Jury Did Not)

›
Yesterday, two defendants caught up in the foreign bank account initiative were convicted in the Southern District of Florida, which seems t...
Tuesday, October 5, 2010

Practitioner Experience with No Answers to the FBAR Question on Form 1040 (10/5/10)

›
Daniel Gottfried posted an article titled Proving Willfulness in FBAR Reporting – Checking “No” Ain’t Apropos . The article is reprinted al...
Saturday, September 25, 2010

State of the Offshore Voluntary Disclosure Initiative

›
Readers interested in the state of the IRS's Offshore Voluntary Disclosure Initiative (OVDI) may be interested in the following publicat...
Wednesday, September 22, 2010

Yet Another UBS Client Bites the Dust

›
On September 21, 2010, Jules Robbins, an 84 year old retired watch distributor, was sentenced to one year probation for hiding his Swiss acc...
3 comments:
Saturday, September 18, 2010

The Triple Whammy from Breach of Trust Illegal Income -- Ouch, That Hurts

›
In United States v. Welch , 2010 U.S. App. LEXIS 19107 (5th Cir. 2010) (unpublished), the Court affirmed a relatively rare upward variance ...

Picky, Picky - Tax Perjury is Not Tax Evasion / Fraud

›
I write just to note that the Third Circuit made a mistake that I hope my students do not make. In United States v. Riley , ___ F.3d ___ (3d...
Friday, September 17, 2010

Another UBS Client Bites the Dust - One Year Sentence (9/17/10)

›
Another UBS client was sentenced today in New York. According to this blog posting by Janet Novack of Forbes' Taxing Matters, Frederico...