A Foot Massage More Painful Than Acupuncture
A Lowell chiropractor was recently sentenced in federal court in the District of Massachusetts for bribing an IRS agent. Stephen Jacobs, age 56, was sentenced by U.S. District Court Judge William G. Young to nine months in prison and ordered to pay a fine of $ 10,000. In October 2014, Mr. Jacobs pleaded guilty to […]
International Data Exchange Service for FATCA Launched
On January 12, 2015, the IRS announced that it had opened a data exchange service for enrollment by financial institutions and countries to use for complying with a U.S. tax law. The purpose of the data exchange service is to facilitate the exchange of information between foreign financial institutions and host country tax authorities, on the one hand […]
What’s In Your Wallet? Uncle Sam Wants To Know
Folks with Panamanian bank accounts may soon be getting some official-looking envelopes in the mail, as the Justice Department recently served John Doe subpoenas on FedEx, DHL, Western Union and a number of other shipping and wire transfer companies. These summonses require the targets to turn over any documents or material relating to their business […]
National Taxpayer Advocate Lambasts IRS’s OVDP Programs and FBAR Penalties
Here ye, here ye! National Taxpayer Advocate, Nina Olson recently gave her annual report to Congress. And she didn’t mince words. She lambasted the IRS for relentlessly asserting onerous offshore penalties including its disproportionate treatment of non-willful taxpayers caught in the labyrinth of foreign asset reporting. Ms. Olson’s report asks the IRS to change its […]
Guideline, Schmideline!
The battleground in the government’s ongoing war against financial criminals shifted to a Brooklyn courthouse last month, as another UBS defendant was sentenced after he pleaded guilty to concealing a foreign bank account. Prosecutors alleged that 73-year-old Gabriel Gabella, an Italian citizen, failed to file a Report of Foreign Bank and Financial Accounts (FBAR) to […]
Making Sense of the Model 2 FATCA Agreement Between Switzerland and the United States and What’s on the Horizon
This article recently appeared in the November/December 2014 Edition of CCH’s Journal of Tax Practice & Procedure: Making Sense of the Model 2 FATCA Agreement Between Switzerland & the U.S.
How To Beat The Rap
Six years into the government’s latest crackdown on offshore tax evasion, federal prosecutors have yet to win a signature jury trial. Of the 38 persons indicted since 2008, 25 have yet to be tried, so the government has plenty of opportunities to bag the heretofore elusive white whale. Most of these 25 defendants are Swiss […]
Walking On Eggshells, Episode II: Attack Of The Fraud Examiners
When we last left our anthropomorphic friends, Rigby was in a serious coma due to an allergic reaction from the eggs in the Eggscelent omelet, and doctors were not optimistic about his chances. Meanwhile, Mordecai discovered a long-lost journal from a former park employee that may hold the key to winning the challenge and the […]
What Do Juries Crave?
Juries wants to do the right thing. They need someone to follow. Who will they follow? According to Gerry Spence, “juries will follow the one they can trust.” As Gerry so eloquently states in his national bestseller, “How to Argue and Win Every Time”: “My experience confirms that everyday people employing their natural credibility detectors can […]
Are the Psychological Benefits of U.S. Citizenship An Adequate Justification For the Worldwide Taxation of Nonresident U.S. Citizens?
I recently wrote a two-part series about the inadequate justification for the United States’ worldwide taxation of its nonresident citizens (Part I is available here; Part II is available here). Professor Michael S. Kirsch offers a different perspective in defense of this system. Instead of assessing the propriety of U.S. worldwide taxation on the basis […]