April 2014

No Laughing Matter: The Criminal Consequences of Failing to Report Foreign Bank Accounts
Listen United States citizens, residents and other persons must annually report their direct or indirect financial interest in, or signature authority over, a financial account that is maintained with a financial institution located in a foreign country if, for any calendar year, the aggregate value of all foreign accounts exceeded $ 10,000 at any time …
Don’t Get Snared in Any of the Three Stages of Money-Laundering
Listen “Money laundering generally refers to financial transactions in which criminals, including terrorist organizations, attempt to disguise the proceeds, sources or nature of their illicit activities.”…U.S. Department of Treasury Website Law enforcement and financial regulators everywhere are on the lookout for money laundering. Big corporations and financial institutions hire compliance experts, and those experts cooperate …
White Collar Crime: Entrapment and Ignorance of the Law Can Snare the Unwary
Listen The most common white-collar offenses run the gamut of nonviolent crimes from antitrust violations to money laundering. The FBI estimates that white-collar crime costs the United States more than $300 billion annually. These estimates do not take into account cases where aggressive and ambitious prosecutors snare an unwary person, who eventually pleads guilty in …
Add the Letter ‘T’ to FATCA, and No One’s Getting Fat Except the IRS
Listen In 2010 President Obama signed P.L. 111-147, the Hiring Incentives to Restore Employment Act. The purpose of the law is in its eponymous title, but the IRS got into the act with the Foreign Account Tax Compliance Act (FATCA) provisions. FATCA is an attempt by the IRS to “improve reporting compliance” — translation: “widen the …
IRS Due Process Collections — Placing a Velvet Glove on the Wrecking Ball
Listen Due process is, according to Black’s Law Dictionary, “a course of legal proceedings … which have been established … for the enforcement and protection of private rights.” Anyone facing an IRS federal tax lien or levy has already experienced the preliminary due process following the IRS determination that more taxes are owed. Said due …