According to Jay Adkisson there are two questions that estate planners commonly ask when they have a client in financial distress: (1) If the Debtor has a history of tithing or making other charitable contributions, can the Debtor continue giving to charity? (2) If the Debtor has a history of making annual gifts to his…
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IRS Seizure of Assets Using Anti-Structuring Laws
According to Procedurally Taxing the New York Times recently reported about a series of cases in which the IRS has seized money from innocent Americans based on purported violations of so-called “anti-structuring” laws, which make it a crime to deposit less than $10,000 cash in the bank in order to evade bank reporting requirements. Carole…
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Is the IRS Office of Professional Responsibility in Decline?
According to taxanalysts.com, in March of 2009, incoming American Bar Association Section of Taxation Chair Karen Hawkins was tasked with taking over the IRS Office of Professional Responsibility. It had been a tough few years for OPR, which struggled with changing professional standards from congressional legislation and a heavy backlog of cases. Hawkins almost immediately revitalized…
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73% of Swiss Banks Want Changes to Their the Terms of the Anti-Tax Evasion Agreement – Non-Prosecution Agreements!
The U.S. Department of Justice (“DOJ“) and the Swiss Federal Department of Finance have entered into an agreement that essentially ends Swiss bank secrecy and the renown of Switzerland as a tax haven (the “PFSB“). The PFSB is monumental because it: Applies not just to American taxpayers but also to foreigners and foreign entities who maintain Swiss…
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