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April 16, 2011 - Phil Hodgen

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 – 1924)].

The parallel to Lawrence Douglas Shulman’s application of the FBAR law could not be more apparent. Multimillionaire tax evaders and immigrant grandmothers of modest means are both treated with exquisite fairness by the Constitution Avenue posse.

Larry Douglas Shulman’s intentions are two-fold:

  • be Congress’s Golden Boy by collecting a lot of money from any source possible; and
  • show US taxpayers that hiding money abroad is a mug’s game.
... continue reading
Americans Living Abroad US Real Estate Investments Voluntary Disclosure
March 21, 2011 - Phil Hodgen

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 whose name was obtained as one of 3,000 people identified in stolen bank data.

Read the article in French or in the passable Google Translate version.

Would we see a judge in the United States do this?  Let’s ask Jack Townsend.... continue reading

US Real Estate Investments
March 15, 2011 - Phil Hodgen

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 who wants a referral, please email me. I will pass along your contact information. (I have the gentleman’s email address).

Here’s the gentleman’s comment:


I am working here on work visa (H1B) from 2008 and for the tax purpose I am a residential alien.

... continue reading
US Real Estate Investments Voluntary Disclosure
March 1, 2011 - Phil Hodgen

You! The guy from London who called!

You called my mobile. We talked. You were aghast and p***** off at the way things are going.

Follow through and tell your story to the ACA.... continue reading

US Real Estate Investments Voluntary Disclosure
February 23, 2011 - Phil Hodgen

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 so cautious?  Read the first paragraph of the linked article and see where Mr. Bagios used to be employed–UBS.

Despite the fact that he is currently a Credit Suisse employee, I still like Bank Julius Baer’s chances as the next Swiss bank piñata for the U.S.... continue reading

US Real Estate Investments