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Category Archives: criminal tax law

Credit Suisse Admits to Conspiring to Hide $4 Billion of US Taxpayer’s Assets in Breach of Its 2014 Plea Agreement

According to DoJCredit Suisse Services AG pleaded guilty and was sentenced on May 5, 2025 to conspiring to hide more than $4 billion from the IRS in at least 475 offshore accounts. The guilty plea by the Swiss corporation is the result of a years-long investigation by U.S. law enforcement to uncover financial fraud and abuse.

In addition to the plea, Credit Suisse Services AG entered into a non-prosecution agreement (NPA) with the Justice Department’s Tax Division and U.S. Attorney’s Office for the Eastern District of Virginia in connection with U.S. Accounts booked at Credit Suisse AG Singapore. Under the NPA, Credit Suisse Services AG agreed to cooperate with the Justice Department in ongoing investigations and to pay significant monetary penalties for maintaining accounts in Singapore on behalf of U.S. taxpayers who were using offshore accounts to evade U.S. taxes and reporting requirements.

According to the Plea Agreement, NPA, and documents filed in court today: from Jan. 1, 2010, and continuing until about July 2021, Credit Suisse AG, which had ultra-high-net-worth and high-net-worth individual clients around the globe, conspired with employees, U.S. customers, and others to willfully aid U.S. customers in concealing their ownership and control of assets and funds held at the bank. 

This enabled those U.S. customers to evade their U.S. tax obligations in several ways, including by opening and maintaining undeclared offshore accounts for U.S. taxpayers at Credit Suisse AG, and providing a variety of offshore private banking services that assisted U.S. taxpayers in the concealment of their assets and income from the IRS and allowed for their continued failure to file FBARs. 

Among Other Fraudulent Acts, Bankers At Credit Suisse Falsified Records, Processed Fictitious Donation Paperwork,
And Serviced More Than $1 Billion In Accounts Without Documentation Of Tax Compliance.

In doing so, Credit Suisse AG committed new crimes and breached its May 2014 plea agreement with the United States.

Between 2014 and June 2023, Credit Suisse AG Singapore held undeclared accounts for U.S. persons, which Credit Suisse AG Singapore knew or should have known were U.S., with total assets valued at over $2 billion. Credit Suisse AG Singapore failed to adequately identify the true beneficial owners of accounts and failed to conduct adequate inquiry about U.S. indicia in the accounts. In 2023, during the post-merger of UBS AG Singapore and Credit Suisse AG Singapore, UBS became aware of accounts held at Credit Suisse AG Singapore that appeared to be undeclared U.S. accounts. UBS froze some of the accounts, voluntarily disclosed information about those identified accounts to the Justice Department and cooperated by undertaking an investigation into the identified accounts.

Under today’s resolutions, Credit Suisse Services AG and, by extension, UBS AG, is required to cooperate fully with ongoing investigations and affirmatively disclose any information it may later uncover regarding U.S.-related accounts. The agreements provide no protections for any individuals. Pursuant to the guilty plea and the NPA, Credit Suisse Services AG will pay a total of $510,608,909 in penalties, restitution, forfeiture, and fines.

Do You Have Undeclared Income from
an 
Offshore Bank or Financial Advisors?
Is Your Name Being Handed Over to the IRS?
Want to Know if Voluntary Disclosure is Right for You?

Contact the Tax Lawyers at 
Marini & Associates, P.A.   
for a FREE Tax Consultation contact us at:
or Toll Free at 888-8TaxAid (888) 882-9243  

Read more at: Tax Times blog

TIGTA Issues IRS Workforce Reduction Report as of March 2025


According to TIGTA IRS Workforce Reduction ReportSince January 2025, there have been several executive orders to reduce the size of the federal workforce. 

In February 2025, the IRS had approximately 103,000 employees. Since then, more than 11,400 IRS employees either received termination notices as probationary employees or voluntarily resigned, representing an 11% reduction to the agency's workforce. 

This is separate from and in addition to IRS Appeals Staffing Cuts and Hundreds of Deferred Resignations.

Specifically:

  • 7,315 probationary employees received termination notices.
  • 4,128 employees were approved to accept the Deferred Resignation Program (an additional 522 employees are pending approval).

This is our first report on IRS workforce reductions and it focuses on the probationary employees identified for termination and the employees who voluntarily participated in the initial Deferred Resignation Program. 

We'll periodically update this report to highlight further reductions, including the impacts of the second Deferred Resignation Program and Reductions in Force.

Have an IRS Tax Problem?

 Contact the Tax Lawyers at
Marini & Associates, P.A. 


for a FREE Tax HELP Contact us at:
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Read more at: Tax Times blog

TIGTA Reports That The IRS Successfully Targeting Rich Non-filers

On November 3, 2020 we posted The IRS Wealth Squad - The Super-Richest's Worst Nightmare, where we discussed that high-net-worth individuals may find themselves the focus of unwanted attention from the Internal Revenue Service. 

Now TIGTA reveals the results of these Internal Revenue Service targeted sweeps of so-called high-income non-filers, which have largely been successful in closing cases and collecting revenue, but the agency could do more to target certain areas and collect tracking data better, the Treasury Inspector General for Tax Administration said.

The Sweeps From 2021 And 2022 Resulted In More Case Closures And Dollars Collected Than High-Income Nonfiler Cases Not Handled Through Sweeps, TIGTA Said In A Report.

HINF sweeps cases worked by revenue officers from Fiscal Years 2021 through 2022 were more impactful in terms of case closures and dollars collected than non-sweeps HINF cases. As a percentage of cases worked, revenue officers secured more returns under sweeps than non-sweeps and referred significantly more returns to Examination. For Tax Years 2014 through 2020, revenue officers consistently collected more per sweep case than non-sweep case. 

Sweeps were conducted throughout the United States and internationally. However, there are several geographic areas in the continental United States that have a high number of HINFs where limited or no sweeps were conducted. There are opportunities for more sweeps in places like eastern New Mexico, western Texas, northwestern Nevada, and Wyoming. 

TIGTA'S review also found that the sweeps tracking data could be improved. Missing, incomplete, and/or inaccurate data were found in data fields such as the taxpayer’s name, address, revenue officer identifier, and case assignment date. These errors were not identified and corrected before this review. We worked with the IRS to make corrections so that the data reviewed for this audit were accurate and complete. However, the IRS would benefit from complete and accurate data to track the results of sweeps. 

Finally, Field Collection is not always using sweeps to help train and develop employee skills. While the sweeps desk guide provides the IRS with many opportunities to develop employee skills, Collection management is not always taking advantage of them. These activities have the potential to make sweeps an even more effective tool.

Are You Being Audited by the IRS Wealth Squad?

Contact the Tax Lawyers at 
Marini & Associates, P.A.
 
for a FREE Tax Consultation
or Toll Free at 888-8TaxAid (888 882-9243)
 


Read more at: Tax Times blog

When Unpaid Taxes Can Cost You Your Passport: The Pfirrman Case


Did you know that owing the IRS can put your passport at risk? That’s exactly what happened to Drew 
Pfirrman, a Florida resident who recently lost his Tax Court case after the IRS certified his “seriously delinquent tax debt.”

What Happened?

·         Unreported Income: The IRS found Pfirrman had over $367,000 in unreported income for 2018 and hit him with a six-figure tax bill, penalties, and interest.

·         IRS Notices Ignored: He missed his chance to challenge the debt through the proper IRS channels.

·         Passport in Jeopardy: When his tax debt grew to over $182,000, the IRS notified the State Department, threatening his passport.

Can You Fight It?

Pfirrman tried to argue that his debt was lower and that partial payments should help. But the Tax Court ruled it can’t reconsider the original tax bill in a passport case. Only full payment of the debt (or qualifying for a special exception) can get your passport privileges restored.

The Lesson

Don’t ignore IRS notices. If you owe big, act fast-set up a payment plan or pay in full. Once the IRS certifies your debt, it’s too late to argue about the amount in court, and your travel plans could be grounded. 

See also our post TC Determines That Taxpayer's Debt Was 'Seriously Delinquent' Even after He Paid Tax to Reduce Balance below $50,000 where we discussed that once a certification of a seriously delinquent tax debt has been made, it may be reversed "if the debt with respect to such certification is fully satisfied." I.R.C§ 7345(c)(1) (emphasis added).

    If You Have Serious Delinquent IRS Debt, You Should Consult with Experienced Tax Attorneys, As There Are Several Ways Taxpayers Can Avoid Having the IRS Request That the State Department Revoke Your Passport. 

  Want To Keep Your US Passport?
 
 
Contact the Tax Lawyers at 
Marini & Associates, P.A.

for a FREE Tax Consultation Contact us at:

or Toll Free at 888-8TaxAid (888)882-9243.

References

1.       https://www.currentfederaltaxdevelopments.com/blog/2025/3/18/irs-properly-certified-seriously-delinquent-tax-debt-to-state-department-leading-to-potential-loss-of-passport             

2.      https://www.thetaxadviser.com/issues/2025/mar/certification-of-seriously-delinquent-tax-debt-not-erroneous/           

3.      https://www.leagle.com/decision/intco20250318g64  

4.      https://www.irs.gov/pub/irs-access/p5827_accessible.pdf   

5.       https://www.irs.gov/businesses/small-businesses-self-employed/revocation-or-denial-of-passport-in-cases-of-certain-unpaid-taxes 

Read more at: Tax Times blog

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