Donna Guerin, 52, a former partner at the now defunct Jenkens & Gilchrist law firm, entered the plea in U.S. District Court to conspiracy to defraud the United States and tax evasion. During the guilty plea proceeding Guerin acknowledged that she knew that the tax shelter transactions would be allowed by the IRS only if…
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Treasury's Assistant Secretary Corwin to Meet with Government Officials to Discuss Efforts to Combat Offshore Tax Evasion in Asia & Europe.
WASHINGTON – The U.S. Department of the Treasury announced today that Deputy Assistant Secretary for International Tax Affairs Manal Corwin will travel to Europe on September 17-21 and to Asia on September 24-28. Corwin will meet with members of the Organization for Economic Co-operation and Development (OECD), members of the Global Forum on Tax and…
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Use of NOL's After Changing Status From Resident Alien to Nonresident Alien
In PLR 201228013, the IRS considered whether an individual who incurred net operating losses (NOLs) while a resident alien could use the NOLs after he became a nonresident alien. The IRS ruled that he could to the extent the NOLs were allocable and/or apportionable to gross income effectively connected with a U.S. trade or business…
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Switzerland Will Allow Grouped Client Disclosure Requests begining in January 2013
The Swiss parliament has agreed that foreign tax authorities will be able to make grouped requests for administrative assistance, specifying suspected tax avoiders by behaviour patterns rather than by name. Unless challenged by foreign clients, the law will come into effect in January 2013. Parliament has approved grouped requests for administrative assistance on tax matters…
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