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Owner of Professional Employer Organization Pleads Guilty to Employment Tax Charge

On Jan. 6, 2017, Janis Edwards, the owner of a professional employer organization, pleaded guilty to tax evasion arising from failing to pay over to the IRS between $3.5 million and $25 million in withholdings that her...more

Digital Currency Exchange Customers Targeted in IRS Information-Gathering Sweep

Coinbase, one of the largest digital currency exchange companies in the world, will likely be asked to provide the Internal Revenue Service (IRS) with transactional data and other information on all U.S. customers who used...more

Tax Delinquencies to Jeopardize Contract Eligibility Under New Final Rule

On Friday, Sept. 30, 2016, the Department of Defense, the General Services Administration and the National Aeronautics and Space Administration issued a Final Rule aimed at blocking tax evaders and convicted felons from...more

Tax Delinquencies to Jeopardize Contract Eligibility Under New Final

On Friday, September 30, 2016, the Department of Defense, General Services Administration and National Aeronautics and Space Administration issued a Final Rule aimed at blocking tax evaders and convicted felons from receiving...more

Heat Rises on Indicted Former Tax Court Judge Diane Kroupa as Husband-Codefendant Pleads Guilty

On September 23, 2016, Robert Fackler, the husband and now co-defendant of former Tax Court Judge Diane Kroupa, pleaded guilty to corruptly impeding the IRS, a felony that carries a maximum three-year prison sentence. It is...more

Treasury and Other Agencies Issue Guidance to Banks on Correspondent Accounts

On Aug. 30, 2016, the Treasury Department, the Federal Reserve, the FDIC, the National Credit Union Administration and the Office of the Comptroller of the Currency issued guidance to U.S. banks that hold correspondent...more

Tennessee Legislator Convicted of Tax Fraud

On August 8, 2016, Tennessee State Rep. Joseph Armstrong (D-Tenn.) was convicted by a federal district court jury of filing a false federal income tax return, and acquitted of tax evasion and conspiracy. Armstrong’s...more

U.S. Tax Court Gives Strong Boost to Computer-Assisted Review

On July 13, 2016, in Dynamo Holdings Limited P’ship v. Comm’r, the U.S. Tax Court strongly defended the taxpayer’s use of computer-assisted review in a dispute with the IRS. In a 2014 decision in the same case, the Tax Court...more

Asset Forfeiture Reform Bill Moving Through Congress

The “Restraining Excessive Seizure of Property through the Exploitation of Civil Asset Forfeiture Tools Act” (tortuously abbreviated as the RESPECT Act) (H.R. 5523) continues to make its way through Congress, with a markup ...more

Is a Hurry-Up Wire Transfer of $3 Billion on Behalf of a Malaysian Government Fund to a Little-Known Private Bank Suspicious?...

Multiple news sources are reporting that the U.S. government is conducting an investigation into whether Goldman Sachs violated the so-called Bank Secrecy Act (real and less-Orwellian name: Currency and Foreign Transactions...more

Reversal of Countrywide Fraud Verdict a Reminder of Government’s Heavy Burden of Proof

On May 23, 2016, the U.S. Court of Appeals for the Second Circuit reversed a jury’s finding of civil fraud against Countrywide Home Loans and other lenders, finding that the government had failed to prove fraud in...more

U.S. Treasury Seeks to Stanch Flow of Proceeds of Corruption and Other Crimes Into Manhattan and Miami Luxury Real Estate

On January 13, 2016, the U.S. Treasury’s financial intelligence unit, known as the Financial Crimes Enforcement Network (FinCEN), announced the issuance of geographic targeting orders (GTOs) to certain unnamed real estate...more

Global Tax Enforcement in 2016: What You Need to Know

The investigation and prosecution of tax evasion has, in the past decade, grown from a specialized subcategory of law enforcement into a first-tier policy concern for the international community. Financial institutions,...more

IRS and DOJ Use a New Method to Defeat Taxpayers’ Fifth Amendment Argument Against Turning Over Foreign Account Records

At virtually every turn, courts have ruled against taxpayers who have asserted their Fifth Amendment privilege against self-incrimination to avoid turning over foreign account records to the government, citing the “Required...more

Congress Passes Law Revoking Passports of Those with “Seriously Delinquent Tax Debt”

On December 3, 2015, Congress passed a bill requiring the IRS to notify the State Department of any taxpayer with “seriously delinquent tax debt” and requiring the State Department to revoke that taxpayer’s passport until the...more

“Unclean Hands” Prevent UBS and Birkenfeld from Recovering Damages from Olenicoff for Malicious Prosecution

On July 23, 2015, the Superior Court in Orange County, California, dismissed a lawsuit brought by UBS and joined by whistleblower Bradley Birkenfeld against former UBS customer Igor Olenicoff. The suit alleged malicious...more

The IRS Turns Up the Heat on Hedge Fund-Backed Reinsurance

After years of inaction, the Internal Revenue Service (IRS) is throwing up obstacles to enjoying the tax advantages of hedge fund-backed reinsurance. On April 24, 2015, the IRS issued a notice of proposed rulemaking titled...more

Global Tax Enforcement in 2015: What You Need to Know

Tax fraud occurs on a considerable scale that can exceed law enforcement’s ability to detect and punish the conduct. This is true at both the federal and state levels. As of 2015, the Internal Revenue Service (“IRS”) and the...more

BSI Is First Bank to Reach Resolution in DOJ’s Program for Swiss Banks

BSI of Lugano, Switzerland, became the first bank to earn a non-prosecution agreement under the U.S. DOJ’s Program for Swiss Banks, paying a penalty of $211 million. First announced on August 29, 2013, the program offered...more

Ex-Credit Suisse Bankers Sentenced to Probation in Exchange for Cooperation

On March 27, 2015, a judge in the Eastern District of Virginia sentenced former Credit Suisse bankers Josef Doerig and Andreas Bachmann to five years of probation. Their sentences were the result of their cooperation with the...more

Update: Banca Privada d’Andorra Succumbs After FinCEN Action

On March 16, 2015, the Spanish subsidiary of Banca Privada d’Andorra, Banco de Madrid, sought bankruptcy protection in the midst of a run on the bank by depositors. ...more

FinCEN Blacklists Banca Privada d’Andorra

On March 10, 2015, FinCEN designated Banca Privada d’Andorra, based in the Principality of Andorra, as a foreign financial institution of primary money-laundering concern pursuant to Section 311 of the USA PATRIOT Act...more

New York Restaurateur Pleads Guilty to Hiding Money in Swiss Accounts

On February 19, 2015, Georges Briguet, the owner of New York restaurant Le Perigord, pleaded guilty to one count of corruptly endeavoring to obstruct the IRS by concealing the existence of his Swiss bank accounts. According...more

2/23/2015  /  IRS , Offshore Funds , Tax Evasion

Former Wegelin Banker Reportedly Arrested on U.S. Warrant in Germany

Multiple outlets are reporting that on February 2, 2015, three years after his indictment in the Southern District of New York, Swiss banker Roger Keller was arrested at the Frankfurt airport. On January 3, 2012, the U.S....more

California Physician Pleads Guilty to Failing to File FBAR for Bank Leumi Account

On February 2, 2015, Baruch Fogel, a California doctor, pleaded guilty in the U.S. District Court for the Central District of California to one count of willful failure to report the existence of a foreign bank account on a...more

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