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Archive for category White Collar Criminal

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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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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Businesswoman Charged With Unreported Israeli Accounts – FBAR Post

by Brian Mahany Opening an account in Israel or any other foreign country is legal. Not filing required FBARs for that account is a crime, however. Guity Kashfi of Los Angeles is learning that lesson the hard way. Prosecutors charged her with conspiracy to defraud the United States, a charge that carries a 5 year [...]

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IRS Extends Willful Blindness To Civil Tax Disputes

by Brian Mahany Willful Blindness has long been a tool of federal prosecutors in a wide variety of criminal tax and drug cases. The doctrine holds that one can’t avoid criminal responsibility by simply ignoring the obvious. For example, drug couriers have unsuccessfully attempted argue that they couldn’t be found guilty of transporting drugs since [...]

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Big Brother IRS Says It Can Read Your Emails Without A Warrant (Tax Evasion Post)

by Brian Mahany According to a recent story published by CNET, the IRS says it doesn’t need a search warrant to read your email. While privacy advocates, liberals, conservatives, the ACLU and courts think otherwise, the IRS still claims that Americans have no expectation of privacy in their emails. I was shocked when reading this [...]

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Unreported Bank Leumi or Mizrahi Tefahot Bank Account? READ THIS (FBAR Post)

by Brian Mahany Unless you are new to this blog, you already know that we write many articles about offshore tax compliance and in particular, the need to disclose foreign bank and financial accounts. Generally, the IRS operates on a first contact policy meaning if you contact them before they find you, it’s possible to [...]

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Indian Business Man Prosecuted For Unreported HSBC India Account (FBAR Post)

by Brian Mahany Although all the media attention on unreported foreign accounts appears to focused on Switzerland, the Justice Department and IRS continue to look worldwide for U.S. taxpayers with undeclared offshore accounts. According to a press release from the United States Attorney’s Office, Sameer Gupta pleaded guilty last week to one count of tax [...]

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Wegelin Postscript – World’s Oldest Bank To Close After Tax Evasion Plea

by Brian Mahany Wegelin & Co. was the world’s oldest bank. Established in 1741, decades before the Revolutionary War, the bank announced it will be permanently shutting its doors. Why? The bank simply could not survive after pleading guilty to U.S. criminal charges that it assisted American taxpayers evade taxes. Wegelin once boasted to depositors [...]

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