Pages

▼
Monday, January 4, 2016

Judge Criticizes Prosecutor's Use of Language Directing Secrecy for Receipt of Grand Jury Subpoena (1/4/16)

›
I hope that all readers of this blog know that grand jury proceedings are generally secret and the grand jurors and government actors in the...
Friday, January 1, 2016

DOJ Tax Authorization of Tax-Related Charges (1/1/16)

›
This is an interesting opinion out of Minnesota.   United States v. Belfrey , 2015 U.S. Dist. LEXIS 170711  (D. Minn. 11/17/15) (Magistrate ...
Thursday, December 31, 2015

Two More Banks Obtain NPAs under DOJ Swiss Bank Program (12/31/15)

›
On December 31, 2015, DOJ announced that 2 more banks have entered NPAs under the DOJ program for Swiss banks,  here .  The penalties, aggre...

Julius Baer Group Ltd. Expects to Pay $547 Million to US to Conclude Criminal Investigation (12/31/15)

›
Julius Baer Group Ltd. ("Julius Baer) expects to pay $547 million to conclude the criminal investigation pursuant to an agreement in pr...
Wednesday, December 30, 2015

Court Orders Compliance with Formal Document Request Upon Taxpayer Motion to Quash (12/30/15; 12/31/15)

›
Section 982, here , authorizes the IRS to issue a formal document request ("FDR") for foreign documentation.  The consequence of a...
Friday, December 25, 2015

NYT Article on CI Investigator Scoring in Drug Investigation (12/25/15)

›
Very interesting article about an IRS CI Agent who identified an online drug czar through unconventional methods.  Highly recommended.  Nath...

Court Rules on Pretrial Motions for Venue, Evidence and Other Matters (12/25/15)

›
In United States v. Barrett , 2015 U.S. Dist. LEXIS 171727 (ED NY 2015), here , the defendant was charged with submitting false claims to th...
Wednesday, December 23, 2015

Five More Banks Obtain NPAs under DOJ Swiss Bank Program (12/23/15)

›
On December 23, 2015, DOJ announced here and here that 5 more banks have entered NPAs under the DOJ program for Swiss banks,  here .  The ...

Interesting Report on U.S. Taxpayer Suit Against Swiss Authorities for UBS Information Turnover (12/23/15; 12/26/15)

›
Swissinfo reports on a case from the The European Court of Human Rights denying a U.S. person relief for the turnover of information from UB...
Tuesday, December 22, 2015

U.S. Taxpayer Seeks Declaratory Judgment that Government Must Prove Willfulness for the FBAR Willful Penalty by Clear and Convincing Evidence (12/22/15)

›
Former Swiss account holders who joined the OVDP program and, upon opt out, are potentially subject to the willful penalty have filed a comp...
Monday, December 21, 2015

Assertion of the Fifth Amendment by a Taxpayer in a Tax Court Deficiency Redetermination Proceeding (12/21/15)

›
What does a party in a civil case do when, in discovery or at trial, the party asserts that party's Fifth Amendment privilege?  The purp...
Friday, December 18, 2015

Two More Banks Obtain NPAs under DOJ Swiss Bank Program (12/18/15)

›
On December 18, 2015, Edmond de Rothschild (Suisse) SA and Edmond de Rothschild (Lugano) SA (collectively EdR Switzerland) reached a joint r...
Thursday, December 17, 2015

Three More Banks Obtain NPAs under DOJ Swiss Bank Program (12/17/15)

›
On December 17, 2015, DOJ announced  here  that Bordier & Cie Switzerland (Bordier), PBZ Verwaltungs AG (PBZ) and PostFinance AG  have ...