Acccording to the DOJ - A jury convicted Arvind Ahuja yesterday on federal tax charges stemming from his failure to disclose offshore bank accounts maintained in India and the Bailiwick of Jersey, the Justice Department and Internal Revenue Service (IRS) announced. Trial began on Aug. 15, 2012 before U.S. District Judge Charles N. Clevert, Jr.,…
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Tax Evasion Potential of Foreign Parent Groups primarily operating in U.S. Analyzed by GAO
A new report by the Government Accountability Office (GAO) has analyzed the prevalence of, and potential tax advantages or abuse stemming from, foreign-parented corporate groups with U.S. subsidiaries that conduct the majority of their worldwide operations in the U.S. Although information on the subject was limited, GAO concluded that this structure may provide an advantage…
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Reliance on Accountant May Provide Reasonable Basis to Avoid Penalty for Failure to File Foreign Trust Form
A district court has denied IRS's motion for summary judgment in a case dealing with the Code Sec. 6677 penalty for failure to file Form 3520, Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts. The court concluded that there was a genuine issue of material fact about whether…
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US Decrypts Swiss Bank Data – Swiss Privacy Regulator Orders Banks to Stop Information Transfer to the US – Swiss Reaction to US Detention of Banker’s Children
Earlier this month, a Swiss bank employee's two children were detained on arrival in the US on a visit to their grandparents, and questioned for several hours about their father's whereabouts. The incident has prompted Switzerland's data protection watchdog to forbid banks to pass any more employee information to the American authorities. Hanspeter Thür has…
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