Tag Archive for Michael DeBlis

What Does The Raoul Weil Case Mean To You?

Iconic mobster Al Capone died in prison after he was convicted of tax evasion. More recently, after the notorious Lufthansa robbery that was immortalized in 1990’s Goodfellas, Jimmy the Gent went to prison not for his alleged role in the robbery but for a point-shaving scandal involving the Boston College basketball team. It could be that crime syndicate figures portrayed by actor Robert De Niro have a certain susceptibility to financial crimes prosecutions, or there could be something else at work.

Tax evasion and other financial crimes in New Jersey are often substitute prosecutions. Traditionally, tax evasion has been easy to prove: there are accurate and timely returns on file, or there are not. “You want to put a murderer in jail for not paying his taxes?” asked a befuddled Elliot Ness in the De Palma version of The Untouchables. Read More

Written by | Posted in Tax Fraud/Evasion/Crimes

Prudence And Caution: The Antidote To The Hazards of Certifying Nonwillfulness Under The Streamlined Procedures

Back on August 13, 2014, the IRS issued an update of the Internal Revenue Manual that sheds some light on what type of submissions might be ripe for audit under the streamlined procedures. For those unfamiliar with the Internal Revenue Manual, it is the “official source of instructions to IRS personnel relating to the organization, administration, and operation of the IRS.”[i] It contains instructions that IRS employees rely upon to carry out their responsibilities, such as procedures for processing and examining tax returns.

The most critical aspect of the update is an instruction that requires submissions containing five or more foreign information returns to be referred for examination.

9. To complete adjustments on Form 1040X filed under the SDO: Read More

Written by | Posted in FBAR • OVDP

Play Ball With The Government Or Else: Marian Morgan Learns Her Lesson The Hard Way

Marian Morgan would not play ball with the U.S. government, and she paid dearly for that decision – a 405-month (almost 34-year) prison sentence. Her codefendants both wound up with very different fates.

Marian Morgan and her husband, John Morgan, ran a Ponzi scheme in Sarasota, Florida, called “Morgan European Holdings,” scamming people out of millions of dollars. They were indicted along with two others, but on more serious charges: one count of conspiracy to defraud the United States, seven counts of wire fraud, five counts of transfer of funds taken by fraud, six counts of money laundering, and three counts of falsifying income tax returns. Read More

Written by | Posted in Tax Fraud/Evasion/Crimes

Swiss Banks Unite And Fire Back At The Department of Justice

Neutrality is Switzerland’s unwritten motto. This devotion to conflict avoidance kept the Swiss out of two World Wars. The Swiss are known for their diplomacy, hospitality, and the ability to keep a secret. So, it came as a shock when 73 Swiss banks joined ranks to inform the U.S. Department of Justice and the IRS, politely but firmly, that they would not be signing a proposed amnesty deal under FATCA.

The Basic Facts of FATCA

In March of 2010, the Department of Justice and the IRS were given a new enforcement weapon. The Foreign Account Tax Compliance Act (FATCA) has three primary objectives regarding foreign financial institutions: Read More

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Ex-Seyfarth Shaw Attorney Case: The Latest in a Series of Department of Justice Prosecutions For Tax Shelter Fraud

Recently, tax shelters have become the target of much prosecution by the Department of Justice. In the largest criminal tax case ever filed, professional services company KMPG LLP admitted to engaging in fraud and generating at least $11 billion dollars in false tax losses. The multi-billion dollar criminal tax fraud conspiracy involved the elaborate design, marketing, and implementation of fraudulent tax shelters.

Since the 2005 KPMG indictment and subsequent guilty plea, the Department of Justice has continued in its quest to uncover instances of tax shelter fraud. The case of Chicago tax lawyer and former Seyfarth Shaw LLP partner, John E. Rogers, is among the latest in a series of tax shelter fraud criminal prosecutions. Starting in 2010, the U.S. Department of Justice targeted John E. Rogers, ex-Seyfarth Shaw LLP partner, with a civil suit alleging he Read More

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Weil Case: What Was The Swiss Role?

If you poke about under rocks for long enough, you’d better be prepared to find something unpleasant. That’s what the US government is realizing as the Raoul Weil case finally goes to court. Weil, 54, is accused of helping US citizens avoid taxes while working as head of Global Wealth Management at Switzerland’s UBS – and some of the stories emerging are as bizarre as the numbers are huge.

Raoul Weil, left, arrives with his wife, Susan Lerch Weil, for the start of his trial at federal court on Tuesday in Fort Lauderdale.

US Clients

It’s thought that UBS’s clients included around 20,000 US citizens, among them, almost Read More

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

Playing Russian Roulette With The IRS: Zwerner Learns The Cost of Hidden Offshore Accounts

Whether you have chosen to hide your account willingly or failed to file an FBAR by mistake, you may not know the full ramifications of your activities or your best course of action now. If you haven’t heard the horror stories yet, you’re about to have a couple to remember. For those who have kept an offshore account secret, there are three options: quiet disclosure, OVDP, or the streamlined offshore procedures. Some may even feel they have a fourth option: keeping the account a secret. The average person may have a hard time deciding what course of action they should take. It may not seem to matter much, but Charles Rettig gives us two frightening examples in his articles, “Jury Determines 150-Percent FBAR Penalty” and “U.S. Seeks FBAR Related Forfeiture of $12 Million!” These stories teach an important lesson, but first, let’s discuss proper offshore account Read More

Written by | Posted in FBAR • International • IRS • OVDP

L.A. Fashion District: The Most Recent Target of the U.S. Government’s Crackdown On Money Laundering And The BMPE

The Los Angeles Fashion District spans 100 blocks, with over 2,000 businesses selling fashions and accessories at 30% to 70% off retail prices.

Saturdays are the busiest Los Angeles Fashion District shopping days, when wholesale-only shops open to the general public. The Sunday shopping epicenter is Santee Alley, between Olympic and Pico Boulevards, where you’ll find low prices, lots of knock-offs and fakes.

Thanks to a recent raid of dozens of businesses in the Fashion District, rock bottom prices and a wide-selection of clothing isn’t all that the Fashion District is now known for. Law enforcement operations have revealed that money laundering activities and Read More

Written by | Posted in Tax Fraud/Evasion/Crimes

Biggest Tax Fraud In History Ends In Sentencing of Ex-Lawyer To Fifteen Years In Prison

In a case dubbed “the biggest criminal tax fraud in history” by federal prosecutors, former lawyer Paul Daugardas was sentenced to 15 years in prison for helping wealthy clients dodge taxes. However, if you blinked, you might have missed it. Why? Mr. Daugedas was sentenced back on June 25, 2014, just a week after the IRS’s historic announcement that it had overhauled the voluntary disclosure program. Therefore, no matter how ground-breaking this story might have been, because it didn’t bear some relation to the major OVDP announcement, it was all but ignored by the media.

I’ve been following the Daugerdas saga ever since U.S. District Judge William Pauley threw out his earlier conviction and ordered a new trial. Right about now, you might be saying, “Wait. Back up. You’re telling me that Daugerdas had been previously convicted of Read More

Written by | Posted in Tax Fraud/Evasion/Crimes

TaxConnections Worldwide Tax Blogs Awards 2014 – Top Twenty Tax Bloggers

TaxConnections Worldwide Tax Blogs gives our readers an opportunity to get to know these tax experts better through their writing. We highly recommend you read TaxConnections Worldwide Tax Blogs to stay informed of emerging tax trends. We highly recommend you interact with our bloggers through your comments on their blog posts. Commenting on a tax bloggers post is a great way to let them know you appreciate the knowledge they have shared. We also recommend you connect with our bloggers on their TaxConnections Microsite. Simply click on their name on their blog post and you will be guided directly to their Microsite where you can connect with them easily on the “ Connect With Me” button.

Here are TaxConnections Top Twenty Worldwide Tax Bloggers:

Peter Scalise
Daniel Erasmus
Harold Goedde
Kathryn Morgan
Hale Stewart
William Richards
Steven Potts
Virginia La Torre Jeker
Michael DeBlis
Annette Nellen
John Dundon
Manasa Nadig
Jerry Donnini
Ronald Cappuccio
Betty Williams
Claire McNamara
Robert McKenzie
James McBrearty

Written by | Posted in TaxConnections
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