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 [...]

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 [...]

For your reading pleasure, here is Notice 2009-62.  If you have signature power over a foreign financial account but the money isn’t yours, then you have an extension of time to deal with the “Come to Jesus!” clean-up and file all of your paperwork with the IRS. If this applies to your particular situation, it [...]

Yesterday I posted about the IRS strategy was in the FBAR amnesty process–a quest to identify other Swiss banks, then go after them hammer and tongs (Caution:  sound file) in order to squeeze names of U.S. taxpayers out of them or scare bank customers into voluntary disclosure. Here’s evidence that the hunting strategy is indeed [...]