‘I Wish I May Never Hear Of The United States Again!’
In a classic example of “be careful what you wish for,” the fictional Lt. Philip Nolan uttered these famous words during his treason trial as Aaron Burr’s accomplice, in Edward Everett Hale’s 1863 propaganda short story – “The Man Without A Country.” As the narrative progresses, and Lt. Nolan is quite literally adrift on an […]
FBAR Due Date Changed
The short-term highway funding extension was passed by the Senate and the House of Representatives and was signed into law by President Obama on July 31, 2015. It contains several important tax provisions (H.R. 3236 (https://www.congress.gov/114/bills/hr3236/BILLS-114hr3236ih.pdf)). The bill changes the due dates for several common tax returns, overrules the Supreme Court’s Home Concrete decision, mandates the reporting of additional information on […]
From Gumshoe To Gavel: The Required Records Doctrine And The Fifth Amendment Act-of-production Privilege Against Self-incrimination for Documents Relating to Foreign Accounts
Although it didn’t have the panache of Dark Justice, a vastly underrated drama, in my humble opinion, the Law & Order franchise was once almost as ubiquitous as stars in the sky or grains of sand on the seashore. These shows featured solid writing and good acting, along with a half cop show/half lawyer show […]
Uncle Sam Enlists Another Collections Agent
India and Pakistan are basically the geopolitical Odd Couple, with a few important differences. First and foremost, Felix and Oscar are fictional. Any conflict between the two is resolved with an exchange of funny one-liners and forgotten by the time the end credits roll. Secondly, despite the show’s title, they do have some things in […]
India Is Next Country on The Verge of Signing Onto FATCA
According to a Reuters article dated Wednesday, July 8, 2015, India and the United States are expected to sign a a tax information sharing agreement today, July 9, 2015, “under a new U.S. law meant to combat offshore tax dodging by Americans.” Excerpts from the article can be found below: “By signing the agreement, India hopes to garner Washington’s support for […]
Rand Paul Files Federal Lawsuit Against U.S. Treasury and IRS over IGA’s
Kentucky Senator and 2016 Republican Presidential hopeful Rand Paul recently announced that, in partnership with Republicans Overseas and five others, he would head to court to stop the vile Foreign Account Tax Compliance Act crackdown. At the risk of comparing the noted Republitarian/Libripublican figure with a certain single-cell cartoon villain, the effort may turn out […]
Take What They Give You
The first half of Super Bowl XX between the Chicago Bears and New England Patriots is painful to watch, for everyone except die-hard fans of Da Bears. Chicago looked like it was playing fifteen guys on defense, and all of them were at or near the line of scrimmage. Several weeks earlier, the Miami Dolphins […]
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, […]
[Don’t] Insert Money Here
It’s no coincidence that churches and banks are usually the two largest buildings in a community. “Filthy lucre,” as the King James so eloquently phrases it, has often reared its ugly head in Christian history. And if you think that the televangelist scandals of the 1980s were a recent development, think again. When Pope Urban […]
Two More Banks Reach Non Prosecution Agreements With U.S. Government
On Tuesday, June 9, 2015, the Department of Justice announced that two more banks had reached non prosecution agreements under the department’s Swiss Bank Program: Société Générale Private Banking (Suisse) SA (SGPB-Suisse) and Berner Kantonalbank AG (BEKB). According to the terms of the agreements, each bank has agreed “to cooperate in any related criminal or civil […]