Archive | July, 2016

International Tax Evasion and Money Laundering: Criminal Prosecutions

July 27, 2016  |   Posted by :   |   Tax Evasion   |   1 Comment

The US Attorney Criminal Resource Manual Sec. 2101, defines criminal conduct for which includes domestic money laundering transaction (18 USC 1956 (a) (1), and international money laundering transaction (18 USC 1956 (a)(2). To be criminally culpable for money laundering a defendant must: 1) Conduct (or attempt to conduct) a Financial Transaction; 2) Knowing that the […]

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Attorney Client Privilege: Crime Fraud Exception

July 25, 2016  |   Posted by :   |   Tax Evasion   |   0 Comments

Under the Crime-Fraud Exception to the Attorney-Client Privilege, a client’s communications to their attorney is not privileged if made with the intention of committing or covering up a “crime or fraud”. Tax crimes (e.g. felonies) for willful evasion of tax, obstruction of tax collection, filing a false tax return may be not privileged under the […]

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US Money Laundering Law and Foreign Tax Evasion

July 20, 2016  |   Posted by :   |   Tax Evasion   |   1 Comment

In the Pasquantino case, (96 AFTR 2d 2005-5392 (2005), the U.S. Supreme Court determined that a foreign government has a valuable property right in collecting taxes and that right may be enforced in a U.S. court of law. Under the CRS Report for Congress, Money Laundering:  An abridged overview of 18 U.S.C. Sec.1956 and Related Federal Criminal […]

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The IRS and Panama Papers – Lessons Learned

July 18, 2016  |   Posted by :   |   Panama Papers,Tax Evasion   |   0 Comments

In a 7/7/16 Hearing before the House Oversight/Government Reform Committee, James B. Comey, FBI Director said: “We don’t want to put people in jail unless we prove that they knew they were doing something they shouldn’t do”. In 2016, the “Panama Papers” named hundreds of thousands of wealthy international investors with offshore accounts (set up […]

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IRS & Panama Papers: US Taxpayers and Criminal Issues

July 13, 2016  |   Posted by :   |   Panama Papers,Tax Evasion   |   0 Comments

Part 1 – US Taxpayers The Panama Papers highlight important IRS issues for US Taxpayers with international (i.e. offshore holdings). Tax issues include: 1) US taxpayers must annually report all of their income both in the US and worldwide. 2) In a divorce action, both spouses must disclose under penalty of perjury, all of their […]

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The IRS Continues its Search for Offshore Tax Cheats

July 11, 2016  |   Posted by :   |   Tax Evasion   |   0 Comments

The IRS is searching thousands of secret records obtained from 80 Swiss banks to determine whether 30,000 US Taxpayers who entered the Streamlined Offshore Voluntary Disclosure Program were truthful. The “SOVDP” was for US taxpayers who claimed they had innocent reasons for failing to disclose off-shore holdings and paid minimal or no penalties (US residents […]

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IRS Tax Evasion Update – July 2016

July 07, 2016  |   Posted by :   |   Tax Evasion   |   0 Comments

Both the IRS and the DOJ are actively hunting down tax cheats: 1. UBS Hands Singapore Client to US 2. Swiss Banker Pleads Guilty to Tax Evasion as IRS Hunts Offshore Accounts 3. F. Lee Bailey, Lawyer for O.J. Simpson, Files for Bankruptcy 4. Las Vegas Dentist Gets 13 Months For Tax Evasion And in international […]

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Money Laundering 2016 – Part 1

July 06, 2016  |   Posted by :   |   Tax Evasion   |   0 Comments

The US Attorney Criminal Resource Manual Sec. 2101, defines criminal conduct for which includes domestic money laundering transaction (18 USC 1956 (a) (1), and international money laundering transaction (18 USC 1956 (a)(2). To be criminally culpable for money laundering a defendant must: 1) Conduct (or attempt to conduct) a Financial Transaction; 2) Knowing that the […]

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