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Archive for category Tax

Update on HSBC Tax Evasion Post – France Provided 24,000 Names To IRS

Just 10 days ago we wrote about Herve Falciani, a French and Italian citizen wanted by Switzerland for allegedly stealing customer account information. Switzerland wants him to stand trial for theft. The Spanish government, however, says the information possessed by Falciani documents widespread money laundering and tax evasion by HSBC clients. Spain’s National Court ultimately [...]

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Musings On IRS Scandal

by Brian Mahany The recent scandal involving the IRS and politically targeted audits has been well covered by mainstream media. I wasn’t even going to write about but for 3 emails from past and present clients. The details of the present scandal are fairly easy to summarize: 1) The IRS targeted conservative and “Tea Party” [...]

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UPDATE: IRS Promises To Obtain Warrants Before Reading Emails

by Brian Mahany 4 weeks ago we wrote a post about an internal IRS search warrant manual that said agents did not need to obtain a search warrant in order to read a taxpayer’s email. This was especially troubling since a federal court of appeals ruled in 2010 that emails shared the same expectation of [...]

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OVDI Offshore Amnesty “Opt Outs” A Good Deal?

by Brian Mahany Spend an hour on the Internet and you will find many self-proclaimed experts suggesting the best way to come into compliance with the IRS offshore reporting rules and avoid steep penalties. Several theories abound including “quiet disclosures”, “opt outs,” “noisy disclosure” and going the amnesty route which involves a one time 27.5% [...]

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Here Come The Vultures – FATCA Post

by Brian Mahany It didn’t take very long. Like vultures circling a dying carcass, shortly after the meltdown of Cyprus’ financial industry, competing tax havens have began soliciting investors. With the implementation of FATCA just months away, there are some important lessons in this story. Cyprus was long a tax haven. Many Russians opened accounts [...]

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