What’s In Your Wallet? Uncle Sam Wants To Know
Folks with Panamanian bank accounts may soon be getting some official-looking envelopes in the mail, as the Justice Department recently served John Doe subpoenas on FedEx, DHL, Western Union and a number of other shipping and wire transfer companies. These summonses require the targets to turn over any documents or material relating to their business […]
Guideline, Schmideline!
The battleground in the government’s ongoing war against financial criminals shifted to a Brooklyn courthouse last month, as another UBS defendant was sentenced after he pleaded guilty to concealing a foreign bank account. Prosecutors alleged that 73-year-old Gabriel Gabella, an Italian citizen, failed to file a Report of Foreign Bank and Financial Accounts (FBAR) to […]
How To Beat The Rap
Six years into the government’s latest crackdown on offshore tax evasion, federal prosecutors have yet to win a signature jury trial. Of the 38 persons indicted since 2008, 25 have yet to be tried, so the government has plenty of opportunities to bag the heretofore elusive white whale. Most of these 25 defendants are Swiss […]
Walking On Eggshells, Episode II: Attack Of The Fraud Examiners
When we last left our anthropomorphic friends, Rigby was in a serious coma due to an allergic reaction from the eggs in the Eggscelent omelet, and doctors were not optimistic about his chances. Meanwhile, Mordecai discovered a long-lost journal from a former park employee that may hold the key to winning the challenge and the […]
What Do Juries Crave?
Juries wants to do the right thing. They need someone to follow. Who will they follow? According to Gerry Spence, “juries will follow the one they can trust.” As Gerry so eloquently states in his national bestseller, “How to Argue and Win Every Time”: “My experience confirms that everyday people employing their natural credibility detectors can […]
What Should A Swiss Banker Charged With Offshore Tax Evasion Do In The Wake of Raoul Weil’s Astonishing Acquittal?
The acquittal of Raoul Weil, the only Swiss banker to have prevailed over the U.S. government in an offshore tax evasion case, has become a source of inspiration for dozens of others who find themselves in a similar situation – indicted and living in Switzerland. As a result, many have become emboldened to come out […]
Should A Convicted Congressman Be Allowed To Keep His Seat In Congress And Continue To Receive Benefits?
Seems like politicians are having a problem staying out of trouble these days. The latest one to “bite the dust” did so in grand fashion, not failing to live up to the hypocrisy that makes for scintillating newspaper headlines. Who was this person? None other than United States Congressman, Michael Grimm. To use a cliché, […]
Court Authorizes IRS To Issue John Doe Summonses For Records Relating to U.S. Clients Who Used A Shell Company To Conceal Offshore Accounts
On December 18, 2014, U.S. District Judge Vernon S. Broderick entered an order authorizing the IRS to issue summonses requiring the following companies to produce information about U.S. taxpayers who allegedly evaded federal taxes by using the services of Sovereign Management & Legal Ltd. (Sovereign): • Federal Express Corporation, doing business as FedEx Express, • […]
Don’t Get Cracked!
In the Emmy award-winning “Regular Show” episode Eggscelent, Mordecai had to eat a 12-egg omelet in under an hour to win a funny-looking trucker hat for his good friend Rigby. Lawyers often face their own eggscelent challenge, but the stakes are quite a bit higher. My colleague Larry A. Campagna, who is a partner at […]
How to Avoid Becoming The Next ‘Cooked Goose’ Gracing The IRS’s Offshore Tax Evasion Table This Thanksgiving
If your name was mentioned in the same sentence as Raoul Weil, Carl Zwerner, or Ty Warner, you can rest assured that you haven’t been nominated for an academy award or a Pulitzer Prize. Nor did you win the Publisher’s Clearinghouse Award. Instead, you’d have joined a disgraced group of taxpayers who have had the […]