According to press reports Credit Suisse, Basler Kantonalbank, Julius Baer, HSBC Switzerland and seven other Swiss banks are poised to turnover data related to U.S. persons suspected of tax evasion or Foreign Bank Account Reporting (FBAR) violations. The story was published on December 18th in SonntagsZeitung, a Swiss newspaper. Supposedly…
The IRS has filed felony criminal tax charges pursuant to Internal Revenue Code Section 7202 for willful failure to collect, truthfully account for and pay over trust fund taxes. This is yet another in a series of criminal tax charges being brought against responsible officers who haven’t paid over corporate…
United States v. Quinn (D. KS 2011) is one of several recent felony tax prosecutions, not for tax evasion, but for violation of Internal Revenue Code Section 7202. IRC Section 7202 makes it a felony to willfully fail to collect, account for, or pay over any tax due. In this…
IRS Fact Sheet 2011-13 (FS -2011-13) has been heavily touted (mostly in the Canadian Press) as providing FBAR (Foreign Bank Account Report) relief for dual U.S. citizens abroad. However, in the view of our tax attorneys it simply reiterates existing law. As readers of the Tax Problem Attorney Blog are…
Brager Tax Law Group appreciates all the votes that came in for our Tax Problem Attorney Blog and is proud to announce that Tax Problem Attorney Blog has been named one of the top 20 Tax Law Blogs by LexisNexis. The voting isn’t over, though. Brager Tax Law Group is…
Until recently even some well-informed tax attorneys assumed that short of disclosure under the Foreign Account Tax Compliance Act (FATCA) in 2013, the IRS would have a difficult time getting information from Swiss banks without litigation. As a result some owners of Swiss financial accounts assumed that they could avoid…
The Swiss Federal Tax Authority (SFTA) has ordered Credit Suisse to submit offshore bank account information in response to an IRS request for assistance, according to a New York Times article. Credit Suisse has notified some of its offshore account holders by letter about the order. Apparently the order is…
Each year, LexisNexis honors a select group of blogs that set the online standard for a given industry. I’m honored that my blog is one of the nominated candidates for the Top 20 Tax Law Blogs of 2011, featured on the LexisNexis Tax law Community. Each comment is counted as…
William H. Nurick, age 76, was convicted of tax evasion based on evidence he evaded a tax liability for one year of $157,000. In 2000 Nurick filed an amended 1995 income tax return admitting a $106,542 tax liability. He then attempted to conceal his offshore financial assets from the IRS…
The UCLA Tax Controversy Institute is the preeminent conference in the United States dedicated to tax controversy and tax litigation. This year it will be held on Tuesday, Oct. 25th beginning at 8:30 AM. This year IRS speakers include: • Sandra Brown, Chief, Tax Division, United States Attorney’s Office (C.D.…