eBook | Foreign Asset Reporting: Navigating the Choppy Financial Seas.

Walking The Sawdust Trail

Those who responded to the altar call after one of Billy Sunday’s sermons were said to walk the sawdust trail, because the temporary venues he preached in back in the 1910s and 1920s often had sawdust on the floor as a deodorizer. Before he became a travelling evangelist, and possibly even before he became a […]

State Offshore Voluntary Disclosure – Because One Tax-osaurus Rex Wasn’t Enough

The Tax-osaurus Rex, or the fearsome offshore voluntary disclosure programs, has made thousands of taxpayers panic since it smashed through the scene a few years ago. While some chose to run and probably ended up torn to parts by vicious raptors (collectors), others are trying to survive by disclosing their foreign accounts and making up […]

Penny Wise And Pound Foolish

Philip Wrigley had a problem. As the notoriously parsimonious owner of the Chicago Cubs in the 1970s, Mr. Wrigley did not want to spend big money to attract top players. But, as the savvy owner of a successful confectionary business, he also knew that no one would buy tickets to see a perennially second-division ballclub. […]

Two More Banks Reach NPAs with the Department of Justice

On June 19, 2015, the Department of Justice announced that two more banks reached resolutions under its Swiss Bank Program. Those banks are Bank Linth LLB AG (Bank Linth) and Bank Sparhafen Zurich AG (BSZ).  According to the terms of the non-prosecution agreements, each bank has agreed to cooperate in any related criminal or civil proceedings, […]

Four More Banks Reach Resolutions with U.S. Government for NPAs

On May 28, 2015, the Department of Justice announced the addition of four banks to its Swiss Bank Program. They are as follows: Société Générale Private Banking (Lugano-Svizzera) MediBank AG LBBW (Schweiz) AG Scobag Privatbank AG   For those unfamiliar with the Department of Justice’s Swiss Bank Program, a slight digression may be in order. The Swiss […]

From Convicted Felon to Government-Made Millionaire: The Man Who Ended the Tradition of Bank Secrecy and Got Rich in the Process

Meet Bradley Birkenfield. Mr. Birkenfield, a former Swiss banker, was released from federal prison three years ago after serving 2½ years for helping wealthy American clients hide millions of dollars from the U.S. government. Five weeks after his release from prison, Birkenfield was sitting on his couch wallowing in his misery, recognizing that he was unemployable as a private banker anywhere. But little did […]

OVDP & Double Counting: Traps for the Unwary

Accounting for “double counting” is not child’s play. Your tax attorney will need the following information in order to complete his or her review of your double counting issue. These steps must be repeated for every year in which you believe that there is a double counting issue. For each transfer, you should provide the following: […]

OVDP And Double Counting: Oh The Agony! – Part II

This is a continuation of Part I. This hypothetical pertains to a taxpayer who has applied to OVDP and who has transferred assets from one foreign account, which was recently closed, to another during the disclosure period. This is a simple example, yet it illustrates some of the common mistakes that are associated with double […]