tag:blogger.com,1999:blog-1519969502186924526.post4428155427174429352..comments2023-10-24T08:00:53.865-05:00Comments on Federal Tax Crimes: IRS Makes Treaty Request for Wegelin Information Involving Asset Management Companies (6/15/13)Jack Townsendhttp://www.blogger.com/profile/14469823736335455874noreply@blogger.comBlogger2125tag:blogger.com,1999:blog-1519969502186924526.post-64161865222074513502013-06-17T13:08:05.238-05:002013-06-17T13:08:05.238-05:00Thanks, anonymous.
Jack TownsendThanks, anonymous.<br /><br /><br />Jack TownsendJack Townsendhttp://www.tjtaxlaw.com/noreply@blogger.comtag:blogger.com,1999:blog-1519969502186924526.post-86847513418275719782013-06-17T12:34:08.109-05:002013-06-17T12:34:08.109-05:00Apparently they are asking for information on acco...Apparently they are asking for information on accounts being managed by portfolio managers not employed by the bank. These are individuals or companies that provide the same service as a managed account at a US broker with the difference is that the account is held at the bank (Wegelin in this case) and the outside firm makes investment decisions. The bank still knows who the account belongs to, (and must follow the same due diligence and identification requirements as when opening an individual account.) Though not mentioned in the article, it would be logical that there would be other criteria, such highest balance during the period over a certain amount.<br /><br /><br /><br />"Suspected of fiscal fraud" in the case of the original UBS request meant " income" above a certain amount per year. Don't recall the specifics of UBS, the amount was probably $100,000 or more, but was arrived at a very sloppy assumption: any sale of an asset was considered "gross income" and it was assumed that the income (for purposed of whether the account would be suspected of fiscal fraud) at 50% of gross proceeds (without bothering to look at the actual gain/loss.)<br /><br /><br />So simply exchanging a large foreign currency deposit into another currency, or cashing a money market fund, or selling a large amount of stock, even if it resulted in minimal actual income or a loss, would be enough to fit the "suspected of tax fraud" definitionAnonymousnoreply@blogger.com