Rambo Judge Grants Mercy to Convicted Foreign Account Holder

In United States v. Purpura , 2012 U.S. Dist. LEXIS 28748 (MD PA 2012), Judge Sylvia H. Rambo granted the convicted defendant's motion to withdraw his plea of guilty to two counts of tax perjury, Section 7206(2) related to a false answer to the Schedule B foreign account question. The opinion is...

Pastor Going to Trial for Tax Charges Predicted Jesus Would Come On May 27

I have previously blogged on Ronald Weinland. See Controversial Pastor, Self Proclaimed Prophet, Indicted re Income from Church Offerings and Offshore Accounts (11/21/11), here . My impression from afar is that he is just a charlatan (see here ) in the guise of a religious person. Just in case he has...

New Indictment of U.S. Tax Return Preparers & Enablers re Offshore Bank & Related Activity

In a First Superseding Indictment, here , filed June 14, 2012 in CD CA, three principals of a tax return preparation service, United Revenue Service ("URS") were indicted. The DOJ Tax Press Release is here, Three Tax Return Preparers Charged With Helping Clients Evade Taxes By Hiding Millions...

Further Guidance on Foreign Financial Asset Reporting

[ Editor's Note: This narrative is derived from Rhoades & Langer, U.S. International Taxation and Tax Treaties, Chapter 9 (Matthew Bender) .] Virtually all individual taxpayers (and certain entities called "specified domestic entities") are required to report their financial assets...

Defendant Waives Attorney-Client Privilege by Asserting Reliance on FBAR Advice Defense

In United States v. Kerr, 2012 U.S. Dist. LEXIS 98836 (D AZ 2012) , a case with two U.S. taxpayers and their lawyer as defendants, the court held that the indicted U.S. taxpayers' claims of reliance constituted a waiver of their attorney-client privilege with respect to communications with their...

Simon's Last Hurrah / Fizzle?

I have posted before on the continuing saga of James Simon, "Certified Public Accountant, a professor of accounting, and an entrepreneur," who was convicted of "filing false income tax returns, failing to file reports of foreign bank accounts, mail fraud and financial aid fraud."...

The Scariest Tax Form? Scary Is in the Eye of the Beholder

Robert Wood has a timely reminder that certain forms, if not filed or filed properly, can create major statute of limitations problems for U.S. taxpayers. Robert W. Wood, Scariest Tax Form? Skip It, And IRS Can Audit Forever (Forbes 3/l3/14), here . The particular form he focuses on is the Form 5471...