Real Estate


Voluntary Disclosure and Frozen Swiss Bank Accounts

I have been long silent on this topic but for those of you who need the information, here it is. Folding The Swiss government and banks are folding like a bunch of cheap patio chairs. Banks have started and will continue to hand over over information about their U.S. customers to the IRS. Expect this […]

Sooner or later, secrecy fails as a tax planning strategy

TL;DR The train is headed straight at you. You cannot tell how far away it is. You can step off the tracks to safety. Alt: you’re naked but you don’t know it yet. British Crown Dependencies and Overseas Territories I know that there are a lot of you out there with corporations, trusts, foundations, and […]

List of international tax forms (first draft)

  Upcoming speech I am going to be giving a one-hour high speed presentation at the 2011 Tax Update and Planning Conference sponsored by the California Society of CPAs. It will be presented in Universal City, San Francisco, and on the web. My hour is intended to give practitioners a checklist approach to the various […]

How the IRS audits attorneys

For those of you concerned about the IRS and your risk factors, please take a look at the Attorneys Audit Technique Guide on the IRS website. Attorney-Client Privilege When Your Attorney Gets Audited For those of you who are deeply concerned about confidentiality and how far the IRS can go in digging into your life, […]

The magnificent equality of the FBAR amnesty

While poking around the interwebs looking for the source of Richard Westin’s quote, I came across this: The law, in its majestic equality, forbids the rich as well as the poor to sleep under bridges, to beg in the streets, and to steal bread. Anatole France, The Red Lily, 1894, chapter 7. [French novelist (1844 […]

French courts exclude illegally-obtained evidence in tax evasion case

The IRS relies on illegally-obtained bank information to fuel its offshore account crusade.  There appears to be no limit on the use of information stolen by ex-employees or others — those doing it for money, conscience, or to spite an ex-employer. A French court has thrown out a tax evasion prosecution of a French citizen […]

H-1B person in need of FBAR assistance

This is a comment on another post on my blog. It is important to give this a more prominent platform, so I did a cut/paste and brought it over here again. If Google hates me because of duplicate content, well, Google, go stick your nose in a dead bear’s bum. Any experienced accountant or lawyer […]

Unaccountably, a Swiss banker travels to the United States

Christos Bagios, a Credit Suisse employee, has been arrested in the United States. This is not legal advice, and I am not your lawyer.  But: Do not travel to the United States.  Ever. If you are flying to South America from Europe, do not change planes in the United States.  Ever. Why would I be […]

If by “entice” you mean “submit and be assimilated” then yes

We know it is coming.  A new amnesty. (Aside.  The IRS people aren’t supposed to use the word “amnesty” in describing the Offshore Voluntary Disclosure Program.  Just like they’re not allowed to use the words “tax protestor.”) In the Jan. 24, 2011 edition of Tax Notes Today, 2011 TNT 15-1, there is a report from the […]