Peter Amrein: The Latest Swiss Banker to Have His Head Put On The Government’s Chopping Block
The Justice Department just recently announced its latest catch: Peter Amrein, a Swiss citizen and former asset manager at a Swiss asset management firm. Mr. Amrein pleaded guilty to one count of conspiracy to defraud the IRS, to evade federal income taxes, and to file false federal income tax returns. By way of his allocution during the […]
BSI SA is First Bank to Reach NPA Under Justice Department’s Swiss Bank Program
On March 30, 2015, the Department of Justice announced that BSI SA, one of the largest private banks in Switzerland, was the first bank to reach a resolution under the Department of Justice’s Swiss Bank Program. Below are excerpts from DOJ’s press release. I have removed the comments from agency officials in order to highlight the more salient points: […]
OVDP And Double Counting: Oh The Agony!
What is this phenomenon known as double counting? Why is it important? If you are shepherding clients through the OVDP program, or you are going through the program yourself, it is critical that you understand what it means and the governing principles behind it. Otherwise, you could be paying an offshore penalty that is exponentially […]
Beware of the Consequences of Avoiding U.S. and Foreign Taxes
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 […]
Ahh … The Sweet Taste of Victory: Withers Wins Victory on Behalf of U.S. Clients Seeking to Renounce Citizenship
In a press release dated March 3, 2015, the Withers Law Firm announced that it was successful in persuading the U.S. Department of State (DOS) to abandon its long-standing position of treating a U.S. citizen who is attempting to renounce his citizenship as being ineligible for a visa to visit the U.S. for business or for pleasure. […]
A Point To Ponder
Most of us remember the good old days of the 1990s – a seemingly decisive victory in the First Persian Gulf War, the dot-com bubble that transformed computer geeks into nouveau riche millionaires, and a string of world championships that made the New York Yankees appear seemingly unbeatable. President Bill Clinton did a good job […]
Further Revisions to Form 8938 Instructions Released
As part of the Foreign Account Tax Compliance Act (FATCA), taxpayers must report “specified foreign financial assets” on a reporting form entitled Form 8938, “Statement of Foreign Financial Assets,” pursuant to Internal Revenue Code section 6038D. Last December 2014, the IRS issued regulations implementing section 6038D. That same month, Form 8938 was updated and revised instructions were issued. Last […]
Former UBS Client Sentenced to Prison for Hiding Offshore Bank Accounts From IRS
Another former UBS client has bit the dust. The Department of Justice recently announced that Gregg A. Kaminsky, an internet entrepreneur who served as CEO of Circlenet LLC, based in Atlanta, Georgia was sentenced for willfully failing to file a Foreign Bank Account Report. Unlike Raoul Weil and a few others who have held the government to its […]
What To Do Next After You’ve Been Pre-accepted Into OVDP
You’ve submitted your OVDP letter and attachments to the Voluntary Disclosure Coordinator and are reclining in your arm chair watching the “big game” while opening up the day’s mail. The upper left-hand corner of one of the envelopes in your pile is adorned with the IRS’s logo. You open it up. The letter is but […]
Raise Your Hands In The Air Like You Just Don’t Care
One of the classic Paper Chase cases, albeit from a different first-year course than the one that the late, great John Houseman taught, is 1891’s O’Brien v. Cunnard S.S. Co., Ltd. Mary O’Brien, an Irish immigrant on board a ship from Queenstown to Boston, held up her arm to be vaccinated against smallpox, a duty […]