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Thursday, August 31, 2017

Deliberate Ignorance Instruction Previously Rejected Allowed Based on Defense Closing Argument (8/31/17)

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In United States v. Walter-Eze , ___ F.3d ___, 2017 U.S. App. LEXIS 16269 (9th Cir. 2017), here , the defendant appealed her convictions for...
Wednesday, August 23, 2017

HMRC Enlists Financial and Other Professionals to Warn UK Citizen Clients About Offshore Accounts (8/23/17)

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Camilla Hodgson, ' Life-changing consequences:' HMRC warns on risks of hiding wealth offshore in new crackdown (Business Insider D...
Monday, August 21, 2017

Agostino & Associates Article on Executor Risks for Decedent's Foreign Accounts (8/21/17)

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Frank Agostino and Nicholas Karp, Protecting the Executor Who Becomes Aware of Undisclosed Foreign Accounts , Agostino & Associates Mont...
Sunday, August 20, 2017

Sixth Circuit Rejects Frontal Assault on FATCA, IGAs and FBAR Requirements (8/20/17)

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The Sixth Circuit on Friday rejected a frontal assault on FATCA, Intergovernmental Agreements and FBAR requirements.  Crawford v. United Sta...
Tuesday, August 15, 2017

Swiss Asset Manager and DOJ Enter Nonprosecution Agreement (8/15/17 8/18/17)

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DOJ Tax and USAO SDNY announced here   and here that it has reached a nonprosecution agreement ("NPA") with Prime Partners SA (“P...
Monday, August 14, 2017

Indictment of Taxpayers for Evasion of Payment and Structuring Cash Withdrawals (8/14/17)

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DOJ Tax announced here the indictment of two Virginia taxpayers -- husband and wife -- for evasion of payment, § 7201, and conspiracy to st...
Wednesday, August 9, 2017

Court Sustains $10,000 Per Year § 6038(b) Penalty for Form 5471 Noncompliance for Taxpayer Who Withdrew from 2009 OVDP (8/9/17)

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In Dewees v. United States , 2017 U.S. Dist. LEXIS 124989 (D.C. D.C. 2017), here , Dewees, a U.S. citizen residing in Canada, was fined $120...
Tuesday, August 8, 2017

USSC Practitioners Advisory Group Recommendations on Sentencing Commission Priorities (8/8/17)

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The Practitioners Advisory Group ("PAG"), here , A Standing Advisory Group of the United States Sentencing Commission ("USSC...

2017 Editions to Townsend on Federal Tax Procedure Available for Download (8/8/17)

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My 2017 editions of my Federal Tax Procedure Book are now posted on SSRN and available for download as follows: Federal Tax Procedure (201...
Monday, August 7, 2017

Tax Practitioners' Advice to Clients About the Audit Profile/Risk (8/7/17)

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I thought readers might be interested in this recent article:  Michael B. Lang and Jay A. Soled, Disclosing Audit Risk to Taxpayers , 36 Va....
1 comment:
Saturday, August 5, 2017

Taxpayer Successfully Shows NonPossession and Control to Avoid Summons and Successfully in Most Part Asserted Fifth Amendment (8/5/17; 8/20/17)

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In United States v. Lui , 2017 U.S. Dist. LEXIS 119953 (N.D. Cal. 2017), here , the court granted in part and denied in part the IRS petitio...
Saturday, July 29, 2017

Another Plea Agreement for Offshore Account (7/29/17; 7/30/17)

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USAO CD CA announced here the plea by a plastic surgeon to one FBAR criminal count.  The relevant excerpts from the announcement are:    ...
Monday, July 24, 2017

Peter Reilly on Conservation Easement Donations as Bullshit Tax Shelters (7/24/17)

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Peter Reilly has a great write up on the conservation easement tax scam -- aka bullshit tax shelter (my description, not his) -- that has fe...
Saturday, July 22, 2017

DC Circuit Reverses Preparer Conviction for Prosecutorial Misconduct (7/22/17)

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I do not spend much time on this blog on return preparer fraud (or stolen identity refund fraud).  But, this case caught my attention United...
Thursday, July 20, 2017

Another Person Indicted for Offshore Accounts (7/20/17)

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DOJ Tax has announced here the indictment of Teymour Khoubian for tax obstruction, tax perjury, false FBARs and false statements.  The des...

Court Dismisses Claims Where IRS Issued JDS Without Required Court Approval for JDS (7/20/17)

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In Hohman v. United States, 2017 U.S. Dist. LEXIS 106439 (ED MI 2017), here, the district court finally dismissed a case where the plaintif...

Credit Suisse Banker Pleads Guilty to Conspiracy (7/20/17)

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DOJ Tax announced here the guilty plea by Susanne D. Rüegg Meier, a former Credit Suisse AG banker, for conspiracy.  I link the Plea Agreem...
Wednesday, July 19, 2017

Second Circuit Decision Applying Fifth Amendment to Foreign Compelled Testimony (7/19/17)

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The Second Circuit issued an important decision today dealing with the use -- directly or indirectly -- of testimony compelled by a foreign...