Tax Evasion

News & Analysis as of

Offshore Accounts? IRS is Watching

If you have unreported income from offshore accounts, now may be the best time to come forward and report those earnings; otherwise, you may be susceptible to criminal prosecution. The IRS initially began this...more

Senator Grassley Urges IRS to Strengthen Whistleblower Program

Both in our practice and on our blog, we typically focus on the SEC Whistleblower Program, which seeks actionable intelligence about possible violations of the federal securities laws. But, the SEC Whistleblower Program is...more

Focus on Tax Controversy and Litigation - Supreme Court Decides Woods v. Commissioner, Holds for IRS on Jurisdictional and...

In this issue: - US Supreme Court Imposes Valuation-Misstatement Penalty in TEFRA Proceeding - Southern District of New York holds Cooperation with Government Waives Attorney-Client Privilege - IRS Issues...more

FATCA: Initial Registration Deadline Extended

On April 2, 2014, the IRS announced that foreign entities that must be FATCA-compliant by July 1, 2014 now have until June 3, 2014 to register with the IRS (as opposed to the previous April 25, 2014 registration deadline)....more

MoFo New York Tax Insights - Volume 5, Issue 4 - April 2014

In This Issue: City ALJ Holds First Amendment Requires Exercise of Discretionary Authority for Sourcing Receipts from Providing Credit Ratings; Tribunal Affirms Partial Day Count for Statutory Residency Purposes; ALJ...more

My, What Long Arms You Have, Uncle

Here’s a visual: Uncle Sam extending his arms around the world, reaching out for his citizens, wherever they may be. He may resemble a candy-striped Gumby, with disproportionately long rubbery arms spanning the globe. The...more

Alberta Court of Queen’s Bench Confirms Rectification Cannot Remedy Unanticipated Tax Consequences

The recent decision of the Court of Queen’s Bench of Alberta in Graymar Equipment (2008) Inc v Canada (Attorney General), 2014 ABQB 154 is an important reminder of the limited nature of the equitable remedy of rectification...more

Levin and McCain Urge DOJ to Seek Extradition of Fugitive Swiss Bankers

Bloomberg news reports that on March 18, 2014, U.S. Senators Carl Levin and John McCain wrote a letter urging the Justice Department to seek extradition of about 30 Swiss bankers and others who are charged with enabling...more

France Tightens Disclosure Requirements for Large Companies, Particularly in Relation to Transfer Pricing

The Anti-Tax Evasion Act and the Finance Act 2014 have introduced an annual transfer pricing documentation filing obligation and new disclosure requirements for large companies....more

Nonresident Alien Who Was Previously a U.S. Resident Indicted for Tax Crimes

On March 20, 2014, a federal grand jury in Kansas City, Missouri indicted Victor Lipukhin for tax crimes that occurred from 2002-2007. What makes this indictment stand out when compared against many others is that the...more

As Swiss Banking Becomes More Transparent, Americans with Undeclared Swiss Accounts Are Warned

In a move that was likely celebrated by United States governmental officials, Swiss banking secrecy eroded even further on Thursday, March 6, 2014. This is the day that parliament voted to provide foreign tax authorities with...more

As the Foreign Accounts Tax Compliance Act Takes Hold, U.S. Sees Expatriates at All-Time High

Are you living the American dream … abroad? If so, you may be considering joining forces with Superman and changing your nationality. You face some unique burdens if you earn a cent while soaking up the sun in Saint Tropezor...more

Senate Report Urges DOJ Action Regarding Offshore Tax Evasion, Enforcement Against Swiss Banks

On February 27, the Senate Permanent Subcommittee on Investigations (PSI) issued a report and held a hearing related to its multi-year investigation of offshore tax evasion and the DOJ’s efforts to pursue Swiss banks who...more

Is Mental Disease or Impairment a defense to “Willfulness” penalties for FBAR purposes?

In a pending civil penalty case in Florida the government puts forth its argument in clear language to describe what constitutes “willful” failure to file a Report of Foreign Financial Account (FBAR). In its Motion for...more

Update: U.S. International Tax Enforcement Efforts

On February 25, 2014 the U.S. Senate Permanent Subcommittee on Investigations, issued its report on its investigation into offshore tax evasion and the participation of Swiss Banks. Specific recommendations were made, among...more

First Lady Of Tax Fraud

The IRS just issued its Criminal Investigation Annual Report. Budget constraints caused the staffing of Special Agents to drop to the lowest numbers in recent history, but 2013 included a 12.5 percent increase in...more

Senate Hearing Takes Aim on Offshore Tax Evasion

Today, February 26, 2014, the Senate Permanent Subcommittee on Investigations will hold a hearing on offshore tax evasion titled “Offshore Tax Evasion: The Effort to Collect Unpaid Taxes on Billions in Hidden Offshore...more

Who Is Next, Now That Swiss Banks Will Turn Over Account Data?

What do you do if your offshore account is at one of 14 Swiss banks currently under criminal investigation? What do you do if your offshore account is at one of the 106 Swiss banks that have entered into non-prosecution...more

Once You Start Bribing – I Guess It Is Hard To Stop

News came out last week that chiropractor Stephen Jacobs of Lowell, MA is in hot water with the feds. Dr. Jacobs allegedly paid an IRS auditor $5,000 in cash to ignore two deductions he improperly took on this 2011 income...more

Hodgson Russ Lawyers Win Residency Case At New York’s Court Of Appeals

As many of our clients and friends learned yesterday, the New York State Court of Appeals has issued its highly-anticipated decision in John Gaied v. New York State Tax Appeals Tribunal. The court’s decision, in a victory for...more

OECD Publishes Standard for International Automatic Tax Information Exchange

On February 13, 2014, the OECD published a standard for the automatic exchange of tax information among governments, intended to help fight cross-border tax evasion. Under the standard, governments would collect information...more

Swiss Investment Adviser to Plead Guilty to Helping Americans Evade Taxes

Multiple outlets are reporting that on February 26, 2014, Martin Lack, a Swiss investment adviser and former UBS banker, will plead guilty in the Southern District of Florida to one count of conspiracy to defraud the United...more

Canada Signs FATCA Intergovernmental Agreement with the United States

Canada and the United States announced on February 5, 2014, that they had signed a long-awaited intergovernmental agreement (Canada–U.S. IGA) that dramatically expands the sharing of tax-related information between the...more

Maine Legislators Take Aim At "Offshore Tax Havens"

Maine legislators have introduced legislation (LD 1120) to “close offshore tax loopholes.” The U.S. Public Interest Research Group’s report, "Closing the Billion Dollar Loophole," estimates that Maine could save $14 million...more

6 Reasons US Taxpayers Should Report Assets Held in Swiss Banks Soon

Initial success of DOJ Swiss bank amnesty program creates greater urgency for US taxpayers. On December 31, 2013, the window to apply for the US Department of Justice’s (DOJ) amnesty program closed for certain Swiss...more

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