‘Close’ Only Counts In…Tax Accuracy Penalty Cases?!
After the California Angels dropped a tough 7-6 decision to the Kansas City Royals (normally reliable reliever Rudy May had a rare bad game, giving up two runs in the bottom of the eleventh inning), baseball great Frank Robinson sagely remarked that “Close don’t count in baseball. Close only counts in horseshoes and hand grenades.” […]
How the IRS Reconstructs Income In Tax Fraud Cases
In one of the climactic scenes from 1954’s On The Waterfront, Crime Commission prosecutors had to make their corruption case against union boss Johnny Friendly (a/k/a Michael Skelly) by convincing a reticent yet pure-hearted Terry Malloy to come forward and tell what he knew about corruption in the International Longshoremen’s Association, beginning with the murder […]
Liability for Trust Fund Taxes
As a rule, workers look forward to payday, even if their meager restitution isn’t as much as they would like it to be. Visions of sugarplums dance in their heads, or at least visions of one less bill emblazoned with the dreaded “Past Due, Please Remit” stamp. As a rule, employers dread payday. Even if […]
Paying U.S. Taxes As An Expat: The New Indentured Servitude?
“The ship Unity, William Glover, Master, Will sail in a Week. Has very good Accommodations for Passengers. Healthy young MEN and WOMEN, as indentured Servants will meet with good Encouragement, and be well treated on board this Vessel. Apply as above.” Thousands of advertisements like this one appeared in English newspapers prior to the American […]
Do I Need To Report Bitcoin On My FBAR?
Many lawyers are borderline technophobes. In 2014, Chief Justice John Roberts wrote that the Supreme Court still used vacuum tubes to distribute messages long after these systems became available in Washington-area yard sales. “Judges and court executives are understandably circumspect in introducing change to a court system that works well until they are satisfied that they […]
The Fifth Amendment’s Essential Role in Offshore Audits
We’ve all seen Matlock reruns, haven’t we? We all sat through a civics class in high school, didn’t we? So we all know what the Fifth Amendment is, right? Therefore, is there any reason at all to finish this article? Before we can begin to understand how the Fifth Amendment applies in offshore tax cases, […]
Justice Department Reaches Final Resolutions Under Swiss Bank Program
The Department of Justice issued the following press release back on December 29, 2016: The Department of Justice announced today that it has reached final resolutions with banks that have met the requirements of the Swiss Bank Program. The Program provided a path for Swiss banks to resolve potential criminal liabilities in the United States, […]
FATCA Brings End to Switzerland’s Time-honored Tradition of Bank Secrecy
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Essential Elements of Tax Crimes
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Tax Crimes That The Government Relies Upon in offshore bank tax prosecutions
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