What Happens in Vegas Stays in Vegas
The catch phrase in the movie Jerry McGuire was “Show Me the Money!” It now looks like prosecutors are adopting the same mantra and are enjoying success in courts indicting those that attempt to hide money and avoid paying taxes either in the U.S. or abroad. In the past, it was a given that an […]
IRS Updates Rules For Foreign LLC’s
The IRS recently updated its rules for foreign LLC’s. The updates can be found here. The relevant portions are contained below: A Limited Liability Company (LLC) is a business structure allowed by state statute. Each state may use different regulations, and you should check with your state if you are interested in starting a Limited Liability […]
From Convicted Felon to Government-Made Millionaire: The Man Who Ended the Tradition of Bank Secrecy and Got Rich in the Process
Meet Bradley Birkenfield. Mr. Birkenfield, a former Swiss banker, was released from federal prison three years ago after serving 2½ years for helping wealthy American clients hide millions of dollars from the U.S. government. Five weeks after his release from prison, Birkenfield was sitting on his couch wallowing in his misery, recognizing that he was unemployable as a private banker anywhere. But little did […]
OVDP & Double Counting: Traps for the Unwary
Accounting for “double counting” is not child’s play. Your tax attorney will need the following information in order to complete his or her review of your double counting issue. These steps must be repeated for every year in which you believe that there is a double counting issue. For each transfer, you should provide the following: […]
Tax Planning on the Edge – Ride or Die in the International Tax Arena
The U.S. economy has become more global, lining up in the race to the top. However, with multinational economic activities revving their gears, some tax practitioners are growing fast and furious. To them, it doesn’t matter if you win by an inch or a mile; winning is winning. As a result, some choose to violate […]
OVDP And Double Counting: Oh The Agony! – Part II
This is a continuation of Part I. This hypothetical pertains to a taxpayer who has applied to OVDP and who has transferred assets from one foreign account, which was recently closed, to another during the disclosure period. This is a simple example, yet it illustrates some of the common mistakes that are associated with double […]
Roll On One
James Moore received a temporary reprieve from a federal judge in Seattle, but, at least metaphorically speaking, he is still strapped onto the mercy seat in classic John Coffey style, waiting to see what the onlooking guards will do next. No one really knows how Moore v. United States will turn out. What we do […]
A Message From Uncle Sam to Those With Foreign Assets: Don’t Forget Your U.S. Reporting Obligations
On April 10, 2015, the IRS issued a press release entitled, “IRS Reminds Those with Foreign Assets of U.S. Tax Obligations.” I’ve attached the relevant portions below: WASHINGTON — The Internal Revenue Service today reminded U.S. citizens and resident aliens, including those with dual citizenship who have lived or worked abroad during all or part […]
Ms. Fournie Shows Fortitude in Fight Against the IRS
Undeclared accounts are the latest bane for Swiss banks, which are being pushed to the brink by U.S. authorities to release details of their U.S. accountholders who park assets there in order to avoid paying U.S. taxes. Many Swiss banks have what are referred to derogatively as, “recalcitrant accountholders.” Recalcitrant accountholders are those who, despite […]
Swiss Bankers Skirt Jail Time in U.S. Tax Evasion Case Thanks To ‘Cooperation Agreement’
A combined fine of $225,000 and five years of unsupervised probation without jail time was handed down to two former bankers of Credit Suisse AG. Josef Dörig and Andreas Bachmann, both Swiss nationals, received the reduced sentence due to their cooperation with U.S. authorities. Their crime: helping U.S. citizens evade taxes. Just one year ago, […]