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Articles Posted in Tax Litigation and Tax Controversy

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Grammy Winner Faces Criminal Tax Charges

Tax problems abound for Lauryn Hill, who won five Grammys for her 1998 debut album. Her album, “The Miseducation of Lauryn Hill,” might describe her alleged actions to stop paying taxes and subsequent consequences. Former member of the Fugees band, Ms. Hill, who’s also an actress, has been charged by…

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Tax Fraud Penalties Upheld First By Tax Court, Then by Ninth Circuit

Tax fraud penalties were recently upheld against Miguel Robleto of Oregon by the 9th circuit. These were civil tax fraud penalties pursuant to IRC Section 6663, not criminal tax evasion charges under IRC Section 7201. The difference is that although you can wind up paying a lot of money if…

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Tax Lawyer Convicted of Aiding and Abetting Tax Evasion

A “tax attorney’s” conviction for aiding and abetting tax fraud I am not sure that makes him a tax attorney). The District Court sentenced the attorney to 30 months in prison and 3 years of supervised release. While this seems like a light sentence don’t forget that the tax attorney’s…

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Prominent Civil Rights Lawyer Disbarred after being Convicted of Tax Evasion, Bankruptcy Fraud & Money Laundering

A controversial Southern California civil rights attorney has been disbarred after being convicted on federal charges of tax evasion, bankruptcy fraud and money laundering, according to the California Bar Journal. Stephen G. Yagman, 66, had been suspended from the practice of law since August 2007, when he was convicted of…

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Julius Baer Offshore Bank Account Information To Be Released

Rudolph Elmer, an ex Julius Baer executive turned over offshore bank account information to WikiLeaks today, according to Bloomberg News. According to the release, data on 2000 offshore bank accounts has been turned over, and WikiLeaks plans on making the data public; although it says it will take at least…

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FATCA Impacts Offshore Bank Accounts (Part II)

Since March of 2009 about 18,000 owners of offshore bank accounts have filed voluntary disclosures with the IRS. So what does FATCA mean to current holders of overseas financial accounts who have not filed FBARs (Foreign Bank Account Reports) on Form TDF 90.22-1, and who have not taken advantage of…

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FATCA Impacts Offshore Bank Accounts (Part I)

FATCA (Foreign Account Tax Compliance Act of 2009) could be one of the final nails in the coffin for offshore banks referred to as foreign financial institutions or FFIs. When I first heard about FATCA after it was passed in March of 2010 I didn’t pay much attention. After all…

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IRS Files Summary Judgment in FBAR Case

In mid-October the IRS filed a summary judgment motion seeking FBAR (Foreign Bank Account Report, Form TDF 90-22.1) penalties of over $225,000 for a civil failure to file an FBAR. This is only the second civil FBAR case that I am aware of which didn’t involve an underlying non-tax crime.…

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IRS Loses Big in FBAR (Foreign Bank Account Report) Case

Last month the IRS lost a case (United States v. J. Brian Williams) in which it tried to impose the 50% penalty for willfully failing to file a Foreign Bank Account Report, TD F 90-22.1 (FBAR). This appears to be the first case that has gone to court on FBAR…

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IRS FBAR Net (Noose?) Tightens to Include Offshore Bank Accounts at HSBC

In February I offshore bank accounts at HSBC had been indicted for FBAR (Foreign Bank Account Report) violations and related tax attorneys had been contacted regarding their clients’ undisclosed foreign bank accounts held at HSBC. Apparently letters had come from Department of Justice prosecutor Kevin Downing who has been taking…

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