The foreign account amnesty is winding down to the last days. If you’re wondering about the payoff for the IRS, look no further. Here’s an example. An attorney and an accountant in Arizona have been indicted for setting up offshore tax structures. This is unrelated to any of my pending cases. But let me guess [...]

All you procrastinators out there, wondering what to do and wondering WHEN to do it? If you want coverage by the voluntary disclosure program currently under way for unreported bank accounts, you have to get to the IRS before they get to you.  I just had one of my applications bounced by the IRS.  Audit [...]

The Criminal Investigations offices are getting really fast at processing initial applications under the voluntary disclosure program.  This week’s speed demon reports:  Boston and Oakland.  Yay!  Think “days” rather than “weeks” to get clearance and your letter saying you’re eligible for the amnesty. The next stop on the the happy road of amnesty applications is [...]

Jack Townsend has — as usual — a thoughtful analysis of the implications of the UBS settlement in which UBS will cough up a few thousand names of U.S. taxpayers.  (Exact details of the settlement haven’t been publicized yet.) It seems clear to me (and to Mr. Townsend) that the settlement depends on the Swiss [...]

According to Reuters, UBS has settled with the IRS.  Names will be named.  (How many?  Yours?  We shall see.)  Beans will be spilled.  Fingers will be pointed.  Bureaucratic chests will be puffed outward. Meanwhile, back on earth. . . . (I have been accused of being obtuse in the past.  By my wife.  Let me [...]