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Wednesday, June 3, 2015

Two More Banks Obtain NPAs Under DOJ Swiss Bank Program (6/3/15)

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DOJ Tax announces here that two more banks have obtained NPAs under the program.  The banks are Rothschild Bank AG and Banca Credinvest SA....
1 comment:

Whistleblower Case Apparently Involving Wegelin (6/3/15; 6/6/15)

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In Whistleblower 21276-13W v. Commissioner , 144 T.C. No. 15 (2015), here , the Tax Court held that the IRS Whistleblower Office must consid...
Monday, June 1, 2015

Third Circuit Reverses Variance to One Day from Guidelines Range of 63 to 78 Months (6/1/15)

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In United States v. Stango , 2015 U.S. App. LEXIS 8286 (3d Cir. Pa. 2015), here , the Third Circuit reversed the sentencing court's sent...
47 comments:
Friday, May 29, 2015

New IRS FBAR Penalty Guidance (5/29/15; 6/1/15; 6/10/16)

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Heather Maloy, Commissioner, LB&I, has issued a memo, dated 5/13/15 titled Interim Guidance for Report of Foreign Bank and Financial Acc...
25 comments:

Former House Speaker Indicted for Structuring and Lying to Federal Agents (5/29/15; 6/3/15)

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Former Speaker of the U.S. House of Representatives J. Dennis Hastert has been indictment for structuring bank withdrawals to evade bank rep...

Basler Reported to Pay $42.1 Million to Settle with Germany Over Undeclared Accounts (5/29/15)

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Reuters reports that Basler Kantonalbank wil pay $42.1 million to settle a German probe into undeclared assets.  Katharina Bart, Basler Kan...
Thursday, May 28, 2015

Article on Government's Use of Tax Returns at Trial (5/28/15)

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Jeremy Temkin, here , has authored an article titled "The Government's Use of Tax Returns at Trial," published in the New Yor...

4 More Swiss Banks Obtain NPAs Under DOJ Program (5/28/15)

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In a news release today, here , DOJ Tax announces that the following banks have reached NPAs under the DOJ Swiss Bank Program, here : Soc...
3 comments:

The FIFA Indictments and Guilty Pleas - the Tax and FBAR Angles (5/28/15)

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Yesterday, amidst great fanfare, DOJ announced the indictment of FIFA officials and others.  See press release titled Nine FIFA Officials a...
Wednesday, May 27, 2015

Urgent - Bureau of Economic Analysis Forms For Foreign Entities Due as Early as May 29, 2015 (5/27/15)

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I have just learned about certain BEA forms due as early as May 29, 2015. The BEA Web Site for the forms is here . A good discussion is ...
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Switzerland Publishes Certain Identifying Information of Certain Foreign Depositors in Swiss Banks (5/27/15)

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When Switzerland makes a decision to turn over bank information of a foreign depositor upon request of a treaty party, the depositor is enti...
Tuesday, May 26, 2015

Guilty Plea for a U.S. Offshore Account Enabler (5/26/15; 5/27/15)

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DOJ Tax has announced, here , a perjury conviction for an Indiana resident, Alexander Krivosuz.  The offense is described cryptically as fol...

Supreme Court Addresses the Wartime Suspension of Limitations Act (5/26/15)

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In Kellogg Brown & Root Services, Inc. v. Carter , 575 US 650 (2015), here , a unanimous opinion handed down today, the Supreme Court he...
Monday, May 25, 2015

District Court Cryptically Rejects Defendant's Arguments on Instructions (5/25/15)

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Trials are messy and the legal principles deployed are often imprecise.  In United States v. Messier , 2015 U.S. Dist. LEXIS 63741 (D. ME 20...
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IRS Establishes Cybercrimes Unit to Combat Solen ID Tax Fraud (5/25/15)

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In its Annual Business Plan for 2014-2017, here , IRS CI announced the following Enforcement Strategy (among others): Cyber Crimes – Crim...
Sunday, May 24, 2015

Recent Round of John Doe Summonses Reported (5/24/15)

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I am catching up with some reading over the holiday.  Among the reading is Lee A. Sheppard, IRS Advertises Offshore Compliance Effort , 2015...
Saturday, May 23, 2015

DOJ Tax Authority to Investigate Tax Crimes Independent of a Grand Jury (5/23/15)

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In a recent posting, Seventh Circuit Ducks On Use of IRS Summons for Criminal Investigation (Federal Tax Crimes Blog 5/11/15), here , I dis...
Friday, May 22, 2015

Article Questioning Effectiveness of U.S. Swiss Bank Initiatives for Past Misdeeds (5/22/15)

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The Economist has an article questioning the U.S.'s claimed success for the U.S. offshore account initiatives from UBS forward.   Ameri...