Office of Chief Counsel Internal Revenue Service Memorandum Number: AM2008-009 Release Date: 8/29/2008 CC:INTL:B01:QPHuynh PRENO-136253-08 UILC: 9114.03-42 date : August 21, 2008 to : Michael Julianelle Director, Employee Plans (Tax Exempt and Governmental Entities) from : Associate Chief Counsel (International) subject : UK Pension Rollovers This memorandum addresses the possible application of Article 18 (Pension…
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Jail & Big Fines for Undeclared Swiss Accounts!
Two former clients of UBS AG were sentenced on Monday to a year and a day in prison, matching what records show as the longest prison term ordered so far in a sprawling investigation of offshore tax avoidance involving the Swiss banking giant. Sean and Nadia Roberts of Tehachapi, California, were also ordered to pay…
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IRS Continues Extreme Pressure on Swiss Banks for More Information
The US government is piling further pressure on Credit Suisse for the release of more information on its clients. Switzerland's Finance Minister Eveline Widmer-Schlumpf says the US is 'constantly making new demands that we cannot accept', thus delaying resolution of their dispute over the prosecution of 11 Swiss banks. If you have a Credit Suisse…
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Trouble for Offshore Bank Account Owners at Liechtensteinische Landesbank AG (LLB)
According to a spokesman for LLB quoted in the article, changes in Lichtenstein law allow the IRS to make group requests without providing the names of the specific individuals that the IRS is seeking. The spokesman also stated that in the Liechtenstein group request, U.S. authorities are also targeting lawyers, accountants, financial advisers, asset managers…
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