Tax Planning on the Edge – Ride or Die in the International Tax Arena
The U.S. economy has become more global, lining up in the race to the top. However, with multinational economic activities revving their gears, some tax practitioners are growing fast and furious. To them, it doesn’t matter if you win by an inch or a mile; winning is winning. As a result, some choose to violate […]
A Message From Uncle Same To U.S. Taxpayers: No One Is Above the Law When It Comes to Filing Timely And Accurate Income Tax Returns
Just in time for the April 15, 2015 tax filing deadline, the IRS issued a press release entitled, “Justice Department Reminds Taxpayers that No One Is Above the Law or Below the Radar.” No further commentary is necessary. The title says it all. Click here to read the article.
IRS-CI Publishes 2014 Annual Business Report
IRS-CI recently published its 2014 Annual Business Report. It contains statistics regarding the conviction-rate for 2014 and is very insightful. Click here to view it.
Facing The Music
When I was a young, fresh-faced criminal defense attorney, there was an aged judge on one of the local benches. Courthouse rumor persisted that this gentleman, whose name I cannot recall, was a finalist to serve as Alf Landon’s running mate in 1936. The judge would occasionally say that his particular fiefdom should be called […]
Swiss Bankers Skirt Jail Time in U.S. Tax Evasion Case Thanks To ‘Cooperation Agreement’
A combined fine of $225,000 and five years of unsupervised probation without jail time was handed down to two former bankers of Credit Suisse AG. Josef Dörig and Andreas Bachmann, both Swiss nationals, received the reduced sentence due to their cooperation with U.S. authorities. Their crime: helping U.S. citizens evade taxes. Just one year ago, […]
Peter Amrein: The Latest Swiss Banker to Have His Head Put On The Government’s Chopping Block
The Justice Department just recently announced its latest catch: Peter Amrein, a Swiss citizen and former asset manager at a Swiss asset management firm. Mr. Amrein pleaded guilty to one count of conspiracy to defraud the IRS, to evade federal income taxes, and to file false federal income tax returns. By way of his allocution during the […]
BSI SA is First Bank to Reach NPA Under Justice Department’s Swiss Bank Program
On March 30, 2015, the Department of Justice announced that BSI SA, one of the largest private banks in Switzerland, was the first bank to reach a resolution under the Department of Justice’s Swiss Bank Program. Below are excerpts from DOJ’s press release. I have removed the comments from agency officials in order to highlight the more salient points: […]
Beware of the Consequences of Avoiding U.S. and Foreign Taxes
The catch phrase in the movie Jerry McGuire was “Show Me the Money!” It now looks like prosecutors are adopting the same mantra and are enjoying success in courts indicting those that attempt to hide money and avoid paying taxes either in the U.S. or abroad. In the past, it was a given that an […]
Ex-Casino Owner, Nevada Businessman and Former NFL Player ‘Bite the Dust’ In Massive Tax Fraud Scheme
If it wasn’t so serious, it has all the makings of a joke with a hilarious punch line: “So this ex-Casino owner and former NFL player are sitting at a bar sipping their gin and reminiscing about old times when …” Only it is. A former casino owner, a former businessman from Las Vegas, and a former […]
Statistics On Tax Prosecutions Published By TRAC
The Transactional Records Access Clearing House (TRAC) recently compiled data that tracked trends showing the number of taxpayers who the government prosecuted as a result of IRS investigations. The article contains charts and tables and can be found here. The second sentence gets the audience’s attention real fast by identifying a common trend: that “many IRS prosecutions are timed to coincide […]