‘I Wish I May Never Hear Of The United States Again!’
In a classic example of “be careful what you wish for,” the fictional Lt. Philip Nolan uttered these famous words during his treason trial as Aaron Burr’s accomplice, in Edward Everett Hale’s 1863 propaganda short story – “The Man Without A Country.” As the narrative progresses, and Lt. Nolan is quite literally adrift on an […]
From Gumshoe To Gavel: The Required Records Doctrine And The Fifth Amendment Act-of-production Privilege Against Self-incrimination for Documents Relating to Foreign Accounts
Although it didn’t have the panache of Dark Justice, a vastly underrated drama, in my humble opinion, the Law & Order franchise was once almost as ubiquitous as stars in the sky or grains of sand on the seashore. These shows featured solid writing and good acting, along with a half cop show/half lawyer show […]
Take What They Give You
The first half of Super Bowl XX between the Chicago Bears and New England Patriots is painful to watch, for everyone except die-hard fans of Da Bears. Chicago looked like it was playing fifteen guys on defense, and all of them were at or near the line of scrimmage. Several weeks earlier, the Miami Dolphins […]
Somebody Got Pinched
Well, so much for honor among thieves, at least as the U.S. government defines the t-word. Swiss bankers felt they had no choice but to violate the two greatest things in life. But this time, the allegations were quite a bit more serious than selling cigarettes without a retail permit, and there was no grinning […]
Red Card
Ever since the United States hosted the World Cup Finals in 1994, soccer has struggled to find a place in the overwhelmingly crowded American sports landscape. So, if you subscribe to the theory that there’s no such thing as bad publicity, the recently-unsealed indictments in New York may be the best thing to happen since […]
Non-prosecution Agreements Galore: Two More Banks Ink NPAs with the Justice Department
On June 3, 2015, the Department of Justice announced that two banks, Rothschild Bank AG and Banca Credinvest SA, had reached resolutions under the department’s Swiss Bank Program. For those unfamiliar with the Swiss Bank Program, it “provides a path for Swiss banks to resolve potential criminal liabilities in the United States.” Banks contemplating such an agreement had until December […]
Game Changer
With all the brouhaha surrounding the Patriots’ win in Super Bowl XLIX this past February, New England’s Bill Belichick effectively cemented his legacy as a brilliant coach, shrewd general manager and impenitent cheater. According to the official deflate-gate report, the team intentionally underinflated game balls in its victory over the Indianapolis Colts in the AFC […]
Addition of Pinter Bank Swells List of Foreign Banks To Which Enhanced OffShore Penalty Applies to Fifteen
Most U.S. taxpayers who enter the IRS Offshore Voluntary Disclosure Program must pay an offshore penalty equal to 27.5 percent of the highest year’s aggregate balance of their offshore accounts during an eight-year look-back period. On August 4, 2014, the IRS increased this penalty from 27.5% to 50% if the following conditions exist: (1) At the […]
What If …
What if Adam and Eve had admitted that they ate from the Tree of Knowledge of Good and Evil, instead of pointing the finger at anyone else, and anything else, that happened to be there at the time? Would they still be lounging in the Garden of Eden today, munching on pomegranates and perusing through […]
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 […]