Backed by court judges, federal prosecutors are issuing subpoenas -- official papers which compel the recipients to provide potentially damning evidence -- to United States taxpayers suspected of holding hidden accounts at Swiss and other offshore banks, according to criminal defence lawyers whose clients have received the papers. The grand jury subpoenas are unusual in…
Read more
IRS Summons? Meet John Doe.
How does the IRS get on to you, you might wonder? Increasingly, one important technique is the John Doe summons. It blew the lid off the hushed world of Swiss banking in 2008 when a judge allowed the IRS to issue a John Doe summons to UBS for information about U.S. taxpayers using Swiss accounts.…
Read more
New Theory for Levying upon LLC Assets in Collections Cases
A standard tool of defense in collections cases has been that the Internal Revenue Service cannot pierce state law entities such as a Single Member LLC. Currently there is a two-part analysis that determines whether the IRS can seize property owned by a Single Member LLC: first the a court must look to state law to…
Read more
Can Foreign Account Nondisclosure Be A Conspiracy?
Can Foreign Account Nondisclosure Be A Conspiracy? - Forbes Any indictment makes you think, and ones based on foreign accounts are increasing. Read more at: Tax Times blog
Read more
