Tax Evasion

News & Analysis as of

Put Another Notch in the DOJ Gun

In the history of the old west when gun fighters survived a gun fight they might put a “notch” in their pistol as a badge of honor. Well the U.S. Department of Justice can put another notch in its weapon of choice, threat of...more

Forensic Accountant and Certified Fraud Examiner Pleads Guilty to Concealing UBS Account

On October 3, 2014, according to a U.S. Attorney’s Office press release and court records, Howard Bloomberg, a forensic accountant and certified fraud examiner, pleaded guilty to one count of failure to file an FBAR reporting...more

Treasury Notice on Inversions Leaves Basic Inversion Transactions Intact

In This Issue: - Deferred Earnings and Profits of CFCs - Code Section 956(e) - Code Section 7701(l) - Code Section 304(b)(5)(B) - Code Section 7874 - Request for Comments -...more

More Tax Lessons from Reality Stars on What Not to Do, Plus Lionel Messi

We discussed last week the surprise when a highly visible reality star is charged with or convicted of tax evasion or other financial crimes (see last week’s post here about The Situation and referencing Richard Hatch). This...more

U.S. Treasury Tries to Clamp Down on Tax Inversions

Lately, the media has focused on tax inversions, most recently when Burger King announced that it will purchase Tim Hortons, a Canadian company, but what are they?...more

United States and Brazil Sign FATCA Intergovernmental Agreement

The United States and Brazil have signed a “Model 1” intergovernmental agreement (“IGA”) with respect to the US Foreign Account Tax Compliance Act (“FATCA”). The Brazilian IGA is intended to simplify FATCA information...more

OECD Publishes Initial Recommendations on BEPS

On September 16, the Organisation of Economic Co-operation and Development (OECD) published a set of recommendations for a coordinated approach to fight tax avoidance by multinational enterprises under the Base Erosion and...more

“The Situtation” for Sorrentinos Getting Worse With Social Media

As many have heard recently, Michael Sorrentino (of MTV’s “Jersey Shore” fame) and his brother Marc were indicted for tax crimes in New Jersey and made their initial appearance in court last week. At this point, no one...more

Lessons from The Situation: Pay your Taxes and Do Not Alter your Accounting Records

Reality stars being charged with tax evasion is always surprising, because not only does the whole television audience see you making money, but the government does, too. The first notable instance was the first winner of the...more

Treasury and IRS Issue Inversion Notice

The Treasury Department and the IRS released Notice 2014-52 (the “Notice”) on September 22nd to limit expatriation transactions. The Notice states that Treasury will issue regulations intended to limit the tax benefits of...more

International Tax News - September 2014

BASE EROSION PROFIT SHIFTING PROJECT RECOMMENDATIONS TO COMBAT TAX AVOIDANCE BY MULTINATIONALS - At the request of the G20 Leaders, the Organisation for Economic Co-Operation and Development (OECD) has been considering...more

Base erosion profit shifting project recommendations to combat tax avoidance by multinationals

At the request of the G20 Leaders, the Organisation for Economic Co-Operation and Development (OECD) has been considering 15 key elements to be addressed by 2015 for a co-ordinated international approach to combat tax...more

Bandfield Confirms Aggressive FATCA Enforcement Tactics

On Sept. 9, 2014, in U.S v. Robert Bandfield et al., federal prosecutors in the Eastern District of New York announced the indictment of a U.S. citizen and others, including offshore corporate service providers (CSPs) and...more

IRS Updates to the Streamlined Compliance Procedures under the Offshore Voluntary Disclosure Program: New Forms Standardize the...

On June 18, 2014, the IRS announced sweeping changes to the 2012 Offshore Voluntary Disclosure Program (OVDP). Since that time, additional clarification on procedural requirements has been issued. Most recently, as of August...more

FATCA Violation Underlies Latest US Tax and Securities Fraud Charges

Indictment demonstrates the strength of US law enforcement efforts to combat offshore fraud and is the first to charge a FATCA violation. On September 9, 2014, in US v. Robert Bandfield, et al., federal prosecutors in...more

FATCA: Trapped by the Land of the Free?

The Foreign Account Tax Compliance Act (FATCA) has been billed as the U.S.’s bold effort to go after tax dodgers and cheats. The picture painted is that of greedy rich people secreting their fortunes in offshore accounts and...more

American Pleads Guilty to Hiding Money in Swiss Bank, Moving Money to Israeli Bank after UBS Scandal

On August 19, 2014, Bernard Kramer pleaded guilty in the Southern District of New York to conspiracy to defraud the United States and filing a false income tax return relating to his concealment of “at least $1.1 million” in...more

Forget About Hiding Money Offshore!

On July 21, 2014 the OECD released the full version of a new global standard for the exchange of financial information in tax matters “OECD\Standard for Automatic Exchange of Financial Account Information in Tax Matters”...more

International Tax Compliance Update: Renouncing U.S. Citizenship to Avoid Taxes: Is It Worth It?

As we have reported previously in recent years the United States has intensified its efforts to force United States persons to disclose assets they hold and income they earn abroad. Two prominent examples of these efforts are...more

Part V - Minimizing Risk Of Criminal Prosicution By Meeting Requirements For A Voluntary Discover In IRM 9.5.11.9

Below is Part 5 of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures....more

Treasury’s FinCEN Proposes Rules Forcing U.S. Financial Institutions to Collect Data for FATCA Reciprocity

On July 30, 2014, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) proposed rules requiring U.S. financial institutions to collect “Customer Due Diligence” information, including identifying the true...more

Part 3 – The Delinquent FBAR Submission Procedures

Below is Part 3 of my partner, Rick Josepher’s, analysis of the new offshore enforcement environment in light of the new 2014 Offshore Voluntary Disclosure Procedures....more

Can an OVDP Participant Set Aside a Closing Agreement on the Theory of Duress?

It has been just over five years since the Internal Revenue Service (“IRS”) offered the first of three offshore voluntary disclosure programs for individuals with undisclosed foreign financial accounts. Since the announcement...more

Banking & Financial Services E-Note

In This Issue: - 70 Countries Agree to Share Bank Information in Tax Evasion Probe - Financial Industry Pushes Back Against Proposed ERISA Requirements - Federal Reserve Proposes Tougher Stress Tests for...more

Offshore Tax Enforcement Update: IRS Unveils Major Changes to Voluntary Disclosure Program

Since the 1970s, U.S. taxpayers with foreign banks accounts have been required to annually report their foreign bank account information to the Department of Treasury on a Report of Foreign Bank and Financial Accounts...more

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