Office of Chief Counsel Internal Revenue Service memorandum Number: 201231001 Release Date: 8/3/2012 CC:PA:04 :DSkinner GL-105093-12 UILC: 7101.00-00 date : April 13, 2012 to : Michael R. Fiore Associate Area Counsel (Boston, Group 2) (Small Business/Self-Employed) from : Mitchel S. Hyman Senior Technician Reviewer, Branch 3 (Procedure & Administration) subject : Bond in lieu of…
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Credit Suisse & Wegelin Client Pleads Guilty to FBAR Violation.
An 83-year-old Massachusetts man who held Swiss bank accounts at Credit Suisse Group AG (CSGN) and Wegelin & Co. pleaded guilty to hiding $5.7 million from U.S. tax authorities. Jacques Wajsfelner admitted in federal court in Manhattan that he failed to file Foreign Bank and Financial Accounts Reports. He will pay civil penalties of $2.84…
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IRS' New Increased Focus on Tax Information Reporting & Withholding
Tax information reporting and withholding requirements are rapidly expanding, including an increased focus on U.S. source income for foreign persons by the Internal Revenue Service, Deloitte Tax LLP said in a reportmade public Aug. 21. This change signals a new direction in the government's focus on tax compliance, Deloitte said. Taxpayers now are confronted with…
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Limited Power of Appointment Not Foolproof In Avoiding Completed Trust Gifts
Using a donors' testamentary limited power of appointment is no longer a foolproof way of guaranteeing that a transfer to a trust will not be a completed gift in the eyes of the Internal Revenue Service, Bessemer Trust officials said Aug. 21 at an American Bar Association Real Property, Trust, and Estate Law Section teleconference.…
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