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
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
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
[ 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
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
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
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
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
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
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
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