News & Analysis as of

Summons Foreign Bank Accounts

Freeman Law

Tax Court in Brief | Lamprecht v. Comm’r | Qualified Amended Return and Foreign Banking Reporting

Freeman Law on

Tax Litigation:  The Week of August 29th, 2022, through September 2nd, 2022 Sparta Pink Property, LLC v. Comm’r, T.C. Memo. 2022-88 | August 29, 2022 | Lauber, J. | Dkt. No. 12114-20 Pressman v. Comm’r, T.C. Summ. Op....more

Whitcomb Selinsky, PC

John Doe Summons Doesn't Violate Attorney Client Privilege

Whitcomb Selinsky, PC on

On April 24, 2020, the U.S. Court of Appeals for the Fifth Circuit published its opinion in Taylor Lohmeyer Law Firm P.L.L.C. v. United States. The Fifth Circuit court held that the Taylor Lohmeyer Law Firm (the law firm OR...more

Holland & Knight LLP

IRS Fishing Expedition Is Successful and Raises Important Attorney-Client Privilege Concerns

Holland & Knight LLP on

The attorney-client privilege is one of the bedrocks of the legal profession. It permits communications between a client and an attorney to remain privileged. The U.S. Supreme Court has stated that by assuring...more

Foley & Lardner LLP

IRS Seeks Identities of Americans with Undisclosed Belize Bank Accounts

Foley & Lardner LLP on

Americans with secret accounts in Belize should take notice: the government is looking for you. The U.S. Department of Justice on September 15 filed a petition in federal court in Miami seeking permission to issue summonses...more

Blank Rome LLP

IRS Targets a Belize Bank with a “John Doe” Summons

Blank Rome LLP on

The Internal Revenue Service will now obtain information on U.S. accountholders at a Belize bank – Belize Bank International Limited (“BBIL”) or Belize Bank Limited (“BBL”). Yesterday, the Justice Department announced that a...more

BakerHostetler

Voluntary Disclosures Lead to John Doe Summonses for Information about U.S. Accounts at Zurcher Kantonalbank and Bank of...

BakerHostetler on

In a sign that the U.S. government continues to aggressively seek information on U.S. taxpayers with non-U.S. bank accounts, the government announced on November 12, 2013, that it had obtained a court order authorizing the...more

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