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Yearly Archives: 2012

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 written to several banks to determine what data has already been transferred to the US Department of Justice and how they justified including telephone numbers and written correspondence.

“We have informed them that we are opening an analysis to verify the legality of the data transmitted to the US,” Thür told the Tages Anzeiger on Wednesday. “Until we have the results, we have demanded that no further bank employee data be sent to the US.”

In April, the Swiss government authorized some banks to transfer records after the US threatened to open criminal proceedings against them.

The data was supposed to be encoded to protect the identity of individuals, but it has since come to light that key information has been pieced together to reveal the names of client advisors and other bank employees.

Dozens of bank workers have sought legal advice, resulting in test cases being launched against the banks involved, the government and the Financial Market Supervisory Authority.

The Swiss Federal Prosecutor’s Office announced on Monday it had dismissed one case, saying there was nothing to indicate any laws had been broken.

Defending the government's April decision to allow the data transfer, Finance Minister Eveline Widmer-Schlumpf told the Tribune de Genève newspaper it was the only way to avoid "destroying workplaces".

If you have Criminal Exposure as a Swiss Bank Employee, contact the Lawyers at Marini & Associates, P.A. for a FREE Consultation at www.TaxAid.usor www.TaxLaw.msor Toll Free at 888-8TaxAid (888 882-9243).

Call US before Uncle Sam finds you!
 

Sources
 
 

 

Read more at: Tax Times blog

Bond in lieu of Notice of Federal Tax Lien

Office of Chief Counsel

Internal Revenue Service




memorandum



Number:


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 Notice of Federal Tax Lien


This Chief Counsel Advice responds to your request for assistance. This advice may

not be used or cited as precedent.

ISSUES

Whether it is appropriate for the Service to accept a collateral agreement and bond in

lieu of the Service’s filing a Notice of Federal Tax Lien (NFTL)?

 

Read more at: Tax Times blog

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 million and restitution of $419,940 and under advisory guidelines, he faces 30 months to 37 months in prison at sentencing on Dec. 20.

Wajsfelner’s former Swiss adviser, Beda Singenberger, was indicted last year on a charge of conspiring to help more than 60 U.S. taxpayers hide $184 million from the Internal Revenue Service in offshore accounts.

Wajsfelner admitted that he held an account in his own name at Credit Suisse in 1995, and Singenberger helped him open one there in 2006 in the name of Ample Lion Ltd. At the end of 2007 the account held almost $5.7 million, court records show.
 

If you have have Unreported Income From a Foreign Bank, contact the Tax Lawyers at Marini & Associates, P.A. for a FREE Tax and/or Criminal Consultation at www.TaxAid.usor www.TaxLaw.msor Toll Free at 888-8TaxAid (888 882-9243).

 

Sources:

Business Week

 

Read more at: Tax Times blog

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 a variety of new reporting responsibilities, including those required under the Foreign Account Tax Compliance Act, Deloitte said.

“The information reporting compliance environment has changed,” the report stressed, noting that in the past, IRS enforcement efforts focused less on information reporting compliance than on income tax compliance.

Accordingly, many companies did not devote extensive resources to compliance in the information reporting area, Deloitte said.

But this has changed. “The IRS and Treasury Department are now firmly focused on the payment and reporting of income paid by companies to U.S. recipients on a worldwide basis,” the report said.

If you have any Tax Information Reporting or Withholding questions, contact the Tax Lawyers at Marini & Associates, P.A. for a FREE Tax Consultation at www.TaxAid.us or www.TaxLaw.ms or Toll Free at 888-8TaxAid (888 882-9243).

 

Read more at: Tax Times blog

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