U.S. tax authorities have awarded $104 million to a whistleblower in a major tax fraud case against Swiss bank UBS AG that widened a government crackdown on Americans avoiding taxes in Switzerland, his lawyers said on Tuesday. This approximately 13% of the amount the Government recovered from UBS ( $780 million in fines, penalties, interest…
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Last Chance for Voluntary Disclosures before FATCA becomes effective in 2013!
January 1, 2013 is the effective date of the Foreign Account Tax Compliance Act (FATCA) and with its implementation the associated FATCA disclosures. FATCA ends historical bank secrecy as previously relied on by many US depositors. In anticipation of FATCA implementation, the IRS, revised its Frequently Asked Questions (FAQs), clarifying many uncertainties in the…
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Severance Pay not subject to Employment Tax Says 6th CA
The U.S. Court of Appeals for the Sixth Circuit today affirmed a federal district court decision that severance payments are not wages for purposes of the Federal Insurance Contributions Act (FICA) tax. In re Quality Stores, Inc., No. 10-1563 (6th Cir. September 7, 2012) This tax decision could have wide business implications since the U.S.…
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No Summary Judgement on Resonsible Party Penalty – CA 6
The Court of Appeals for the Sixth Circuit has reversed a district court's Summary Judgment decision that a company's President and CEO/Chairman were liable for the Code Sec. 6672 penalty, finding that there were legitimate factual disputes regarding whether they acted recklessly in failing to pay the trust fund taxes. Notably, although the two were…
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