Tax Law

Recent Posts

DC Court Rejects Bankers Attack on FATCA Regs
Posted on 3 Feb 2014 by Jack Townsend

In Fla. Bankers Ass'n v. United States Dep't of Treasury, 2014 U.S. Dist. LEXIS 3521 (D.D.C. 2014), here , the court sustained the IRS regulations "the regulations requir[ing] U.S. banks to report the amount of interest earned by accountholders... Read More

Reporting Specified Financial Assets and Form 8938
Posted on 18 Dec 2012 by Neil Aragones

U.S. taxpayers with assets overseas and their advisers should be mindful of new Form 8938, Statement of Specified Foreign Financial Assets , as they prepare the taxpayers' federal income tax returns for 2011. Temporary Regulations issued in December... Read More

FATCA (Foreign Account Tax Compliance Act) Proposed Regulations
Posted on 26 Jun 2012 by Pamela Revak

The most recent proposed Foreign Account Tax Compliance Act (FATCA) regulations are designed to lighten the due diligence and compliance burden on foreign financial institutions and U.S. withholding agents, especially with respect to high value accounts... Read More

Further Guidance on Foreign Financial Asset Reporting
Posted on 3 Jul 2012 by Rufus Rhoades

[ 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"... Read More

Convictions of Mail Fraud, False Claims and Conspiracy; Use of Offshore Accounts
Posted on 2 May 2012 by Jack Townsend

According to a DOJ Press Release, Curtis Morris and Richard Kellog Armstrong were convicted of "for mail fraud, filing false claims against the United States and conspiracy to file false claims against the United States." "Morris was found... Read More

Suellen Wolfe on Offshore Voluntary Disclosure Initiatives
Posted on 15 Aug 2012 by LexisNexis Tax Law Community Staff

By Suellen Wolfe, J.D., LL.M.* The Internal Revenue Code requires U.S. taxpayers to report income and pay taxes on worldwide income. [ IRC §§ 61 , 861 , 862 , 863 , 864 , 865 . See also, IRS Publication 17 at Part Two, 5 (2011).] Intentionally... Read More

New Indictment of U.S. Tax Return Preparers & Enablers re Offshore Bank & Related Activity
Posted on 18 Jun 2012 by Jack Townsend

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... Read More

Defendant Waives Attorney-Client Privilege by Asserting Reliance on FBAR Advice Defense
Posted on 23 Jul 2012 by Jack Townsend

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... Read More

Another UBS Depositor Pleads Guilty
Posted on 4 May 2012 by Jack Townsend

Yesterday, Humberto Gomez pled guilty, according to a DOJ Tax press release, here [the link is not yet available; I will post the link when I have it]. ... The tax loss seems low. The press release says: "For the years 2006 and 2007, the criminal... Read More

Another Plea Involving Offshore Accounts
Posted on 23 Feb 2012 by Jack Townsend

DOJ Tax has this press release, Tennessee Couple Plead Guilty to Tax Crimes , cryptically reporting a plea by two taxpayers, husband and wife, to two counts of willful failure to file income tax returns ( Section 7203 ). In relevant part, the press release... Read More

Pastor Going to Trial for Tax Charges Predicted Jesus Would Come On May 27
Posted on 31 May 2012 by Jack Townsend

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... Read More

Further Guidance on Foreign Financial Asset Reporting
Posted on 3 Jul 2012 by Rufus Rhoades

[ 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"... Read More

FATCA (Foreign Account Tax Compliance Act) Proposed Regulations
Posted on 26 Jun 2012 by Pamela Revak

The most recent proposed Foreign Account Tax Compliance Act (FATCA) regulations are designed to lighten the due diligence and compliance burden on foreign financial institutions and U.S. withholding agents, especially with respect to high value accounts... Read More

Suellen Wolfe on Offshore Voluntary Disclosure Initiatives
Posted on 15 Aug 2012 by LexisNexis Tax Law Community Staff

By Suellen Wolfe, J.D., LL.M.* The Internal Revenue Code requires U.S. taxpayers to report income and pay taxes on worldwide income. [ IRC §§ 61 , 861 , 862 , 863 , 864 , 865 . See also, IRS Publication 17 at Part Two, 5 (2011).] Intentionally... Read More

Reporting Specified Financial Assets and Form 8938
Posted on 3 Apr 2012 by Neil Aragones

U.S. taxpayers with assets overseas and their advisers should be mindful of new Form 8938, Statement of Specified Foreign Financial Assets , as they prepare the taxpayers' federal income tax returns for 2011. Temporary Regulations issued in December... Read More