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The Sentencing Sophisticated Means Enhancement Is Not Easy to Avoid

The critical Sentencing Guidelines calculations for tax cases require a two step enhancement to the Base Offense Level for "sophisticated means" in the commission of the crime of conviction. S.G. 2T1.1(b)(2), here . Observers of the tax crimes scene have noted for some time that it does not...

Bank Frey Executive and Swiss Lawyer Indicted

The USA for SDNY has announced, here , the indictment of Stefan Buck, head of "Bank 1" (Bank Frey), and Edgar Paltzer, a partner at a Swiss law firm, a dual U.S.-Swiss citizen, and a registered attorney in NY. (A copy of the indictment is here .) According to the press release, they "are...

John Doe Summons Issued to Wells Fargo for Records of CIBC FirstCaribbean International Bank Correspondent Account

DOJ has announced, here , that a district court approved John Doe Summons for records of CIBC FirstCaribbean International Bank's correspondent account at Wells Fargo, N.A. The goal of the summons is to "allow the IRS to identify U.S. taxpayers who hold or held interests in financial accounts...