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Tag Archive for tax evasion

Higher Court Decision Confirms – FATCA Is Here To Stay

The linchpin legislation of the U.S. government in its effort to combat tax evasion abroad over recent years has been the Foreign Account Tax Compliance Act (FATCA). Last week, the latest legal challenge to FATCA was thwarted when the United States Court of Appeals for the Sixth Circuit affirmed a lower court’s decision to dismiss the case against FATCA.

Quick FATCA Background Read more

Is That Gift Taxable? – IRS Form 709

John Dundon

The IRS instructions to Form 709 Gift Tax Return spell out the general rules for allocating the unified credit to prior gifts. For 2017, the annual gift tax exclusion is $14,000.  That means you can give up to $14,000 to as many different people as you want as a gift without being subject to gift tax rules. Read more

IRS Targeting Foreign Corporations Which Do Not File!

Ron Marini

Tax practitioners will face new questions from examination teams as the IRS selects compliance risks based on data, in the Large Business and International Division’s (LB&I) move from individual audits of multinationals to broader considerations involving risk assessment. Read more

Offshore Tax Suit Switch From OVDP Doesn’t Block Collection

Ron Marini

Three taxpayers seeking to switch over to the IRS’ new “streamlined” compliance program for unreported offshore income argued to a D.C. Circuit panel Tuesday that their lawsuit is not foreclosed by the Anti-Injunction Act’s bar on pre-enforcement tax challenges, attacking the government’s key defense in the case. The case is Maze et al. v. Internal Revenue Service et al., case number 16-5265, in the U.S. Court of Appeals for the District of Columbia Circuit.

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Tax Justice Network Finds The Necessary $70 Billion

William Byrnes

Forgive the alarmist headline. But I just read Tax Justice Network (TJN)/ITEP defending FATCA again because it can raise $40 billion to $70 billion tax revenue a year for the U.S. Enough already. I hope that Tax Justice/ITEP are correct and that $70 billion a year remains to be recovered by the IRS from non-reported foreign income.

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Argentina Signs Information-Sharing Agreement With The U.S.

Ron Marini

The agreement, in which Argentine officials said they were pursuing in September, is part of a government crackdown on alleged tax evasion by individuals. Argentina also has implemented a tax amnesty plan to recover an estimated $500 million in assets held abroad.

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A Holiday Summons A Tale Of Grinches, Princes, Bankers, Toymakers, And Offshore Tax Evasion

Ron Marini

Dave Breen’s, the acting Director of Villanova’s Low Income Taxpayer Clinic, view regarding the case of Greenfield v U.S., which focuses on a recent IRS setback in a summons enforcement case out of the Second Circuit.

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Consultation For Advisors For Potentially Aggressive Tax Planning Schemes

William Byrnes

This consultation aims to gather views on whether there is a need for EU action aimed at introducing more effective disincentives for intermediaries engaged in operations that facilitate tax evasion and tax avoidance and in case there is, how it should be designed.

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The Unknown Tax Comic – Part 22

A little humor with some tax jokes on TaxConnections Tax Blogs.

♦ A tax attorney defended a case of tax evasion for an affluent client. He devoted over a year to the case, familiarizing himself with every loophole and angle of current legislation, and made a brilliant argument before the court. His client was called out of town when the jury returned with its verdict, a sweeping victory for his client on every count. Flushed with victory, the lawyer exuberantly sent an email to his client, “Justice has triumphed!” The client immediately emailed back, “Appeal at once!”

♦ “Ignore them and they’ll go away” is great advice for some of life’s annoyances. Unfortunately, it doesn’t apply to taxes. – Martha C. White

♦ I’ll tell you some tax jokes because I think you’d depreciate them! Read more

10 Tax Sins That Could Land You In Jail

Carelessness on your tax return might get you whacked with a 20% penalty. But that’s nothing compared to the 75% civil penalty for willful tax fraud and possibly facing criminal charges of tax evasion that if convicted could land you in jail.

It’s one thing to make an innocent mistake on your taxes, or to overlook a tax break that could lower what you owe the IRS. While such innocent mistakes will still cost you, they usually won’t invoke the ire of the IRS to pursue criminal prosecution or assess a Civil Fraud Penalty.

When you intentionally disregard tax law, however, such willful neglect will get you in real trouble. The IRS defines “willfulness” as a voluntary, intentional violation of a known Read more

Pistachio Importer Says “Ah Nuts” and Makes Plea Deal for FATCA Violations

The U.S. government charges an owner of an Iranian pistachio processing and distribution company with operating an unlicensed money transmitting business, failing to disclose foreign bank accounts and filing a false tax return.

In United States of America vs. Ali Amin the government alleged that Ali Amin, who wholly owned and operated Primex International Trading Company Inc. (Pitco), had approved the illegal transfer of approximately $600,000 from Iran to the U.S., and concealed unreported income of about $1.93 million for 2009 through commercial transactions involving the purchase and sale of Pistachios with related parties who transferred funds between each other using an informal network (often known as a Hawala). The Indictment illustrates how the system worked: Read more

Tax Court Finds That IRS Did Not Prove Fraud, Therefore Statute of Limitations Was Closed!

On April 6, 2015, following a trial in Tampa, Florida, the Tax Court ruled that back taxes and penalties imposed upon Mr. Jacoby were unfounded because they had not acted fraudulently in the filing of tax return.

The Court’s ruling overturned the IRS’s assessment of approximately $2 million in back taxes and penalties for positions taken by the taxpayers on their 1999 and 2000 tax returns relating to tax shelters promoted by KPMG and others.

Judge Juan F. Vasquez rules that Steven F. Jacoby, who worked as a licensed securities broker and account executive before starting his own financial strategies company, hadn’t intended to evade tax through concealing, misleading or otherwise preventing the Read more

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