As the Department of Justice continues its efforts to prosecute individuals involved in offshore tax evasion, approximately two dozen indicted Swiss bankers remain fugitives in Switzerland. Although the United States and Switzerland have an extradition treaty, Switzerland will not extradite individuals accused of tax crimes. While these individuals are free […]
In the first part of this post, we posed the question of how far the IRS can go back into your past when conducting tax audits. As we noted, the IRS by no means has a blank check to do this. Generally the limitation is three years, or up to […]
Tax Day has come and gone, and usually comes the time of the year when people start to worry about their taxes potentially being flagged by the Internal revenue Service. An audit is possible, though the likelihood of such a reality is very low. Still, it is good to be […]
A former Swiss banking executive has pleaded guilty in a Florida court to charges of helping U.S. clients evade taxes. Hansruedi Schumacher, who cooperated with the U.S. government and testified in another prominent offshore prosecution, will face sentencing later this year. Schumacher, 56, was the Regional Market Manager for UBS’s […]
The Foreign Account Tax Compliance Act (FATCA), a U.S. law passed in 2010 that requires foreign financial institutions to exchange information with the IRS about American account holders, is set to face challenges in both the courts and in Congress. Since 2012, the Treasury Department has negotiated Intergovernmental Agreements with […]
“Don’t look back” is a memorable line in literature. It is the title, for example, of a notable documentary from the 1960s about a high-profile British concert tour by the enigmatic singer Bob Dylan. We may all agree that, in general, it is best to focus on the future. But […]
Two former Credit Suisse bankers have received extraordinarily light sentences after pleading guilty and cooperating with the Department of Justice in its case against the Swiss Bank. Josef Dörig and Andreas Bachmann were each sentenced to five years’ probation and a fine, sentences that are substantially lower than the recommendations […]
Swiss bank BSI SA has admitted to helping U.S. clients evade taxes and entered into a non-prosecution agreement with the U.S. Department of Justice, in a deal that requires the bank to pay a $211 million penalty and turn over the names of 3,000 American account holders. They are the […]
If federal authorities accuse you of tax fraud, the steps you and your attorney take in response are crucial. Given the complexity of the tax code, it is important to get counsel from an experienced tax attorney who knows how to defend and resolve criminal tax charges. In this post, […]
In the first part of this post, we outlined the basic considerations involved in defining when an organization is “closely held” for tax purposes. In this part of the post, we will look in more detail at how the Tax Court and the IRS have differed recently in interpreting and […]