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

‘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 […]

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 […]

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 […]

Somebody Got Pinched

Well, so much for honor among thieves, at least as the U.S. government defines the t-word. Swiss bankers felt they had no choice but to violate the two greatest things in life. But this time, the allegations were quite a bit more serious than selling cigarettes without a retail permit, and there was no grinning […]

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 […]

Roll On One

James Moore received a temporary reprieve from a federal judge in Seattle, but, at least metaphorically speaking, he is still strapped onto the mercy seat in classic John Coffey style, waiting to see what the onlooking guards will do next. No one really knows how Moore v. United States will turn out. What we do […]