tag:blogger.com,1999:blog-1519969502186924526.post3487035661402491175..comments2023-10-24T08:00:53.865-05:00Comments on Federal Tax Crimes: Reciprocity -- the U.S. Issues John Doe Summonses to Identify Norway Tax Cheats (7/29/13).Jack Townsendhttp://www.blogger.com/profile/14469823736335455874noreply@blogger.comBlogger3125tag:blogger.com,1999:blog-1519969502186924526.post-3200974963043233172013-07-31T13:36:33.856-05:002013-07-31T13:36:33.856-05:00Several of the banks listed are not exactly major ...Several of the banks listed are not exactly major financial institutions (with the exception of JP Morgan Chase and Wells Fargo.) It seems plausible that they were approached by Norwegians who happened to be in the US on vacation or visiting relatives and opened an account saying it was needed for convenience (as is the case for Canadian snowbirds, for example.) And the news article says that "There is no suggestion in the DOJ’s court filings that any of the U.S. institutions have done anything improper." <br /><br /><br /><br />And yet if a foreign bank opens an account for an American, DOJ press releases state that the bank conspired to aid the US person in evading US taxes and hiding the money from the IRS. Yet when a non-resident foreigner opens an interest bearing account at a US bank, they sign IRS form W-8 so that no taxes are withheld from the account AND therefore no 1099 is provided to the IRS. Therefore the IRS knows nothing about these accounts, not the interest income and not even the account's existence. There is no withholding on interest on US Treasury bills for nonresident foreigners, either.Anonymousnoreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-60533867193154713802013-07-29T19:44:50.687-05:002013-07-29T19:44:50.687-05:00The addendum did answer a few questions of mine on...The addendum did answer a few questions of mine one of which is how involved is DOJ Tax in all of this. The answer is it appears very. Still I question how much of this is a one off deal or whether we will see more cases like this.<br /><br /><br /><br />All in though DOJ Tax can't be completely thrilled is it takes at least a little bit of sting out of the current cases vis a vis the Swiss bank. <br /><br /><br />One additional question I do have though is how involved are the local US Attorney's in these types of cases. I know they can be overruled by DC but it is pretty rare.Tim12278noreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-36051528083919799032013-07-29T12:42:19.069-05:002013-07-29T12:42:19.069-05:00It is possible that some of these accounts may tur...It is possible that some of these accounts may turn up no breach of Norwegian law, for example someone in the US may be supporting his elderly parents in Norway and letting them use his ATM card. <br /><br />There is of course the big difference between the request for the identity of the holders of US-issued ATM cards that have been used with high frequency in Norway, and the blanket requests of the US for foreign banks to identify accounts held by US citizens with balance over a certain threshhold. For this reason the number of accounts involved is likely to be small, and seems to be more a token gesture on the part of the US than a big move towards reciprocity, but who knows?<br /><br />What would be big news would be if the US were to require the turning over of all accounts over $500K held by Mexicans, Chinese, and Russians. Even bigger news would be if these banks had to pay fines to Norway for helping Norwegians evade Norwegian taxes.Anonymousnoreply@blogger.com