Archive for Michael DeBlis, III

[Don’t] Insert Money Here

It’s no coincidence that churches and banks are usually the two largest buildings in a community. “Filthy lucre,” as the King James so eloquently phrases it, has often reared its ugly head in Christian history. And if you think that the televangelist scandals of the 1980s were a recent development, think again.

When Pope Urban II proclaimed the First Crusade in 1095, the stated mission – freeing Jerusalem and other holy sites from the grip of infidels – was really only a smokescreen. Many historians agree that the Pope’s real mission was to prop up the decaying Byzantine Empire, and specifically regain the fertile regions of Anatolia, and restore the lucrative East-West trade routes through that area of the Middle East. Read More

Written by | Posted in FATCA • Religion • Tax Fraud/Evasion/Crimes

State Offshore Voluntary Disclosure – Because One “Tax-osaurus Rex” Wasn’t Enough

The Tax-osaurus Rex, or the fearsome offshore voluntary disclosure programs, has made thousands of taxpayers panic since it smashed through the scene a few years ago. While some chose to run and probably ended up torn to parts by vicious raptors (collectors), others are trying to survive by disclosing their foreign accounts and making up for previous tax returns and FBAR transgressions. Unfortunately, federal raptors aren’t the only terrors that’ll drive you behind a kitchen counter; ‘friendly’ state raptors are sniffing taxpayers out.

“You Just Went and Made a New Dinosaur?”

Well, the few states with state income tax were tempted to get a piece of the IRS’s action. After all, taxpayers who didn’t report their interest income from an undisclosed Swiss account probably didn’t report it for state tax purposes. Therefore, if you’re amending Read More

Written by | Posted in TaxConnections

Red Card

Ever since the United States hosted the World Cup Finals in 1994, soccer has struggled to find a place in the overwhelmingly crowded American sports landscape. So, if you subscribe to the theory that there’s no such thing as bad publicity, the recently-unsealed indictments in New York may be the best thing to happen since internationally-renowned striker and noted metrosexual David Beckham joined the Los Angeles Galaxy in 2007.

The indictments certainly weren’t good news for the 14 people named in the court documents; six of which have already entered guilty pleas. The list is a veritable who’s who at Fédération Internationale de Football Association (FIFA) and Confederation of North, Central American and Caribbean Association Football (CONCACAF). Of particular note to fans are the allegations that these FIFA luminaries accepted blood money in Read More

Written by | Posted in FATCA • FBAR • IRS • Tax Fraud/Evasion/Crimes

4 More Banks Reach Resolutions With U.S. Government For NPAs

On May 28, 2015, the Department of Justice announced the addition of four banks to its Swiss Bank Program. They are as follows:

• Société Générale Private Banking (Lugano-Svizzera)

• MediBank AG

• LBBW (Schweiz) AG

• Scobag Privatbank AG

For those unfamiliar with the Department of Justice’s Swiss Bank Program, a slight digression may be in order. The Swiss Bank Program was unveiled on August 29, 2013. Read More

Written by | Posted in FBAR • Tax Fraud/Evasion/Crimes

Game Changer

With all the brouhaha surrounding the Patriots’ win in Super Bowl XLIX this past February, New England’s Bill Belichick effectively cemented his legacy as a brilliant coach, shrewd general manager and impenitent cheater. According to the official deflate-gate report, the team intentionally underinflated game balls in its victory over the Indianapolis Colts in the AFC Championship Game. Apologists were quick to point out that New England barely needed a football to dismantle the Colts in that contest, and that may very well be true. But, if deflating the balls did not give the Patriots a competitive advantage, one can be fairly certain that it never would have happened in the first place.

People who know more about this subject than me state that an underinflated football is easier to throw and catch, especially in cold weather, and easier to grasp overall. Since Read More

Written by | Posted in Tax Fraud/Evasion/Crimes

IRS Issues Updated Guidance For FBAR Penalties

The IRS recently issued a memorandum entitled, “Interim Guidance for Report of Foreign Bank and Financial Accounts (FBAR) Penalties.” As explicitly stated in the memorandum, its purpose is to improve the administration of the IRS’s FBAR compliance program. How so? By implementing new procedures. This guidance affects two specific IRMs: 4.26.16 and 4.26.17.

For those who thought that the IRS might have waited a couple months before making these procedures effective so as to allow tax practitioners sufficient time to get up to speed and to work out any “kinks,” that was wishful thinking. Far from enacting a “grace period,” these new procedures went into effect the very day they were published, which just so happened to be May 13, 2015. Thus, this guidance is effective immediately and Read More

Written by | Posted in FBAR • IRS

Non-prosecution Agreements Galore: Two More Banks Ink NPAs with the Justice Department

On June 3, 2015, the Department of Justice announced that two banks, Rothschild Bank AG and Banca Credinvest SA, had reached resolutions under the department’s Swiss Bank Program.

For those unfamiliar with the Swiss Bank Program, it “provides a path for Swiss banks to resolve potential criminal liabilities in the United States.” Banks contemplating such an agreement had until December 31, 2013 to notify the Department of Justice that they had reason to believe that they had committed “tax-related criminal offenses in connection with undeclared U.S.-related accounts.” Banks that were already under criminal investigation (as well as any individuals who worked for these banks) were, to put it mildly, up a creek without a paddle. Very simply, they were ineligible to participate in the program.

Read More

Written by | Posted in Tax Fraud/Evasion/Crimes

Consequences of Internal Renenue Service Tax Compliance for Offshore Residents

Since the time the IRS announced the revised Offshore Voluntary Disclosure Program, there has been a consistent restlessness among American expats. At the forefront of this change is the inclusion of the Streamlined Compliance Procedure Program, which is available to U.S. individual taxpayers residing in the United States as well as those who live abroad.

The Streamlined Foreign procedures cater to those U.S. citizens or lawful permanent residents – i.e., expats – who satisfy the non-residency requirement. The non-residency requirement has two strands. First, the taxpayer must not have a U.S. abode. And second, the taxpayer must have lived outside of the U.S. for at least 330 full days in at least one (or more) of the most recent three years for which the U.S. tax return due date (or properly Read More

Written by | Posted in OVDP

Pinter Bank Swells List of Foreign Banks To Which Enhanced OffShore Penalty Applies

Most U.S. taxpayers who enter the IRS Offshore Voluntary Disclosure Program must pay an offshore penalty equal to 27.5 percent of the highest year’s aggregate balance of their offshore accounts during an eight-year look-back period. On August 4, 2014, the IRS increased this penalty from 27.5% to 50% if the following conditions exist:

(1) At the time the taxpayer initiated their disclosure, one or more of the following applies:

a. A foreign financial institution at which the taxpayer had an account had been publicly identified as being under investigation, the recipient of a John Doe Summons or is cooperating with a government investigation, including the execution of a deferred prosecution agreement or non-prosecution agreement; or Read More

Written by | Posted in OVDP

What If…

What if Adam and Eve had admitted that they ate from the Tree of Knowledge of Good and Evil, instead of pointing the finger at anyone else, and anything else, that happened to be there at the time? Would they still be lounging in the Garden of Eden today, munching on pomegranates instead of apples and perusing through YouTube videos on their iPads?

What if a small team of British commandos had been unable to disable Nazi Germany’s deuterium oxide factory in Vermork in 1943, after several prior attempts had failed? Would Hitler have gained the final component he needed for an atomic bomb, and attached these weapons to the V-2 rockets falling from the sky onto London?

What if that Star Destroyer captain had blown R2-D2’s escape pod to smithereens in the Read More

Written by | Posted in Audit
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