Due Diligence
Posts Tagged IRS
Armageddon For Holders Of Unreported Swiss Accounts
by Brian Mahany
I am amazed at the number of people who are sitting on the fence when it comes to deciding how to handle unreported foreign bank accounts. Although most of our clients never had any criminal intent to defraud the government, the prospect of paying the IRS a 27.5% amnesty penalty or electing to [...]
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Have An Unreported Foreign Account At HSBC? Uncle Sam May Come Knocking!
by Brian Mahany
HSBC is the world’s second largest bank. They claim 100 million customers in 7,500 offices in 87 countries. They also just reported to the SEC that they may be facing serious criminal and civil penalties.
For several years, HSBC has been the subject of several investigations. Last year the IRS reportedly served them with [...]
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IRS’ Taxpayer Advocate Critical of Her Agency!
by Brian Mahany
The Taxpayer Advocate Service is an independent voice within the IRS. It’s mission is to help taxpayers who believe they are lost in the system and not getting the treatment and service they deserve. Looking over the shoulder of an agency of almost 100,000 employees, Taxpayer Advocate Nina Olson is a very busy [...]
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John Doe Summons Powerful Weapon in IRS Arsenal
by Brian Mahany
Most folks have never heard of a “John Doe” summons. According to the Internal Revenue Manual (the IRS’ own internal procedures manual), a John Doe summons is “is any summons where the name of the taxpayer under investigation is unknown and therefore not specifically identified.”
Until the UBS investigation in 2008, very few [...]
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Lawyer Indicted For Helping Clients Set Up Offshore Swiss Bank Accounts
by Brian Mahany
The IRS and U.S. Department of Justice show no sign of letting up in their quest to ferret out U.S. taxpayers with unreported offshore accounts. Earlier this week Justice officials unsealed an indictment against a former San Diego tax attorney and two of his clients for alleging hiding millions in unreported Swiss bank [...]
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Right to Remain Silent in Offshore Asset Cases? NO Says Appeals Court!
by Brian Mahany
Our 5th amendment privilege against self - incrimination is a basic fundamental right guaranteed by the Constitution. Americans can trace this protection from government abuse of authority all the way back to 1215 and the Magna Carta. Think of growing up watching TV shows and movies where the cops tell the bad guy [...]
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Should You Consider an Offshore Account?
by Brian Mahany
About a week ago, I received an email from Doug Casey of Casey Research. The email discussed the benefits of opening an offshore account. His email brings up an important reminder. Often we receive calls from folks who have unreported offshore accounts. They often ask if they should close the account and repatriate [...]
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Swiss Amend Law To Permit More Info Sharing
by Brian Mahany
Switzerland has amended its financial disclosure laws to permit increased exchange of financial information with non-Swiss authorities. The latest move is limited to investigations related to the financing of terrorism and money laundering.
While Americans and others with unreported foreign accounts may be breathing a sigh of relief, the U.S. government frequently adds one [...]
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Swiss Account Holders Beware!
by Brian Mahany
UBS is old news. In recent months we have reported on investigations by the IRS and the U.S. Department of Justice into Credit Suisse, Wegelin, Kantonbank, Clariden Leu, Basler and Julius Baer. In November a former Justice Department official said the list was up to 17 banks. According to a new article by [...]
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Questions About FATCA? You Are Not Alone
by Brian Mahany
We no sooner than release a simple post on the new FATCA financial asset reporting requirements and immediately the emails and calls pour in. It seems as if there are more questions than answers.
Major tax law changes always create questions and uncertainty in the first few years after enactment. The new FATCA reporting [...]
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