LexisNexis® Legal Newsroom
Statutes of Limitations for FBAR Noncompliance Related to Tax Noncompliance

A person commenting on an earlier blog asked the following question (modified slightly for clarity): Does the statute of limitations for the FBAR penalty (both civil and criminal) toll if the taxpayer is outside the U.S.? I answered at least the criminal part of the question in a comment reply...

A New Proposal to Promote American Manufacturing

In recent years U.S. multinationals have restructured themselves in a manner that allows them to greatly reduce their worldwide tax bill. This restructuring has been described in detail by the OECD andil and by the Joint Committee on Taxation . In a March 15 presentation at a conference on taxation and...

Principal Comments on Unclaimed Deductions and Losses in Sentencing Tax Loss Determinations

The Sentencing Commission has received comments and testimony from principal constituents as to the issue of whether unclaimed deductions and credits should be permitted to reduce the tax loss in the critical tax loss calculation for sentencing purposes. The sentencing tax loss, like the loss in other...

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...

Securities Brokers Get Another Reporting Compliance Break

IRC Section 6045 provides the broker reporting rules for certain securities, including debt instruments and options. Generally, for debt instruments acquired on or after January 1, 2013, brokers are required, when reporting the sale of the debt instrument to the IRS, to report the customer's adjusted...

Valuation of Artwork for Federal Estate Tax Purposes

Before valuing items of art, [ Estate of Elkins v. Comm'r , 2013 U.S. Tax Ct. LEXIS 6 (T.C. Mar. 11, 2013) ] held that pursuant to IRC Section 2703(a)(2) , the court would disregard an agreement made by the decedent by which he had waived his right to institute a partition action with respect to...

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...