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Tuesday, September 27, 2011

Another UBS Client Pleads -- With the Baggage of Illegal Income (9/27/11)

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Michael A. Hase, a former comptroller for the U.S. Agency for International Development, has pled guilty to Theft of Government Property and...

The Willfulness Element of Tax Crimes (9/27/11)

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A commenter to one of my other blog entries mentioned the excellent article in today's Wall Street Journal - Gary Fields and John R. Ems...
25 comments:
Monday, September 26, 2011

Update on RRSPs in OVDI (9/26/11)

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This blog entry reviews a Tax Notes Today article -- Marie Sapirie, Clarification of Retirement Plans Need in OVDI , 2011 TNT 186-4 (9/26/11...
78 comments:

Sentencing - Plea Bargaining and the Right to Trial (9/25/11)

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As tax crimes practitioners know, the vast majority of tax crimes indictments end in a plea agreement. This is true of federal crimes gener...
1 comment:
Saturday, September 24, 2011

Tax Crimes and Money Laundering (Particularly Defense Attorney Fees) (9/24/11)

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In United States v. Blair , 661 F.3d 755 (4th Cir. 2011), here , cert. denied 2012 U.S. LEXIS 4469 (U.S. 2012), the Fourth Circuit opens wit...
Tuesday, September 20, 2011

Voluntary Disclosures of Foreign Financial Account and Related Matters After OVDI 2011 (9/20/11)

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The IRS has posted contact information for persons desiring to make noisy voluntary disclosures. See Voluntary Disclosure Contacts in IRS C...
20 comments:

DOJ Tax Web Site Touts DOJ Tax and IRS Juggernaut on Foreign Financial Accounts (9/20/11)

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DOJ Tax has a new web page titled "Offshore Compliance Initiative," here .  The page touts DOJ Tax's efforts and the strategic...
4 comments:
Saturday, September 17, 2011

Diverting Corporate Earnings - Constructive Dividends or Wages / Salary (9/17/11)

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One of the common ways of cheating on taxes is to divert corporate earnings from a C corporation to an entity that is off the IRS's rada...
5 comments:

The Object of a Klein Conspiracy and Specificity (9/17/11)

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In United States v. Mubayyid , 658 F.3d 35 (1st Cir. 2011), here , the First Circuit addressed the issue of the nature of the Klein conspira...
1 comment:
Friday, September 16, 2011

IRS Promotes the Success of OVDI and Related Items (9/16/11)

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As suspected, the IRS is promoting the success of the most recent offshore initiative -- OVDI 2011.  I will use this blog to post items in t...
73 comments:
Wednesday, September 14, 2011

Experiences Inside OVDP / OVDI #1 (9/14/11)

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This blog is created for users to share, by their comments, their experiences inside the OVDP / OVDI programs.  I know the IRS touts that th...
304 comments:
Tuesday, September 13, 2011

The Noose Tightens: Swiss Banks Deliver Up Data (9/11/11)

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Ten of the more significant Swiss bank players in assisting U.S. taxpayers hide their income from U.S. tax authorities have delivered statis...
11 comments:
Saturday, September 10, 2011

Materiality and Corruptly in Tax Obstruction under Section 7212(a) (9/10/11)

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In United States v. Bonds , 2011 U.S. Dist. LEXIS 96051 (ND CA 2011), the jury had found Barry Bonds guilty of obstruction of justice in vio...

Opting Out Considerations - A Jeff Neiman Guest Blog (9/10/11)

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The OVDP and OVDI programs have come to an end and many taxpayers who participated in the programs are about to get their tax bill from Uncl...
7 comments:

Rumors of Additional Grand Jury Subpoenas and John Doe Summonses Against Foreign Banks (9/10/11)

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Jeff Neiman has a new blog entry, Reuters: Enforcement Action Against Ten Swiss Banks in the Works (9/10/11), here , reporting on a Lynnley ...
7 comments:

IRS Continues Mining the Gold from Voluntary Disclosures, and Picks Off a Liechtenstein Bank (9/10/11)

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Lynnley Browning for Reuters reports today that USAO SDNY "a re building a criminal-fraud case against Liechtenstein's oldest bank,...
9 comments:
Tuesday, September 6, 2011

The Swiss Hogs Get Slaughtered, Perhaps (9/6/11)

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The Swiss defense now is to have the pot (the Swiss) call the kettle black (more on the metaphor, here ). The Swiss Bankers Association ...
9 comments:

Burden of Proof for Willfulness in FBAR Violations (9/6/11)

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A key issue in considering the FBAR willfulness penalty is the standard standard of proof if the Government pursues the FBAR penalty. The Go...
23 comments: