On June 30, 2014, the Israeli Finance Ministry signed an intergovernmental agreement with the United States which provides for both countries to exchange information on financial accounts held by their respective citizens in the other’s country. The agreement makes Israel the 28th country to sign a Foreign Account Tax Compliance (FATCA) accord with the United […]

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For generations, Swiss banks have been known around the world for their strict tradition of client confidentiality and privacy. However, recent international agreements aiming to fight tax evasion and end banking secrecy, such as Switzerland’s 2012 agreement with the Organization for Economic Cooperation and Development (OECD) or the Foreign Account Tax Compliance Act (FATCA), have […]

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On July 9, Ashvin Desai, a medical device manufacturer from California, was sentenced to six months in prison and a single day of home confinement after failing to report more than $8 million in foreign bank accounts. Desai was convicted of the charges in the US District Court for the Northern District of California in […]

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Most people are unaware that they can buy investment real property in the pension and profit sharing plans sponsored by their business. (Exception: not if you or a related party occupy the property. That would be a prohibited transaction, subject to a 15% non-deductible excise tax and the requirement to unwind the transaction.) For those […]

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In general, (i) the proceeds of a life insurance policy do not vest with the beneficiary until after the insured dies; and (ii) only in very specific and unusual circumstances does a non-beneficiary become entitled to policy proceeds. This is an example of one case that fits these unusual circumstances. In 1986 Thomas Walkowiak bought […]

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In the case of Roscoe Jerome McNealy and Leanna Yvonne McNealy v. Commissioner of Internal Revenue, the US Tax Court recently issued a summary opinion which granted the commissioner’s motion for summary judgment and denied the McNealy’s alimony deduction claimed on their 2009 federal income tax return. The case involves the McNealys who, when filing […]

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In February of this year we blogged about a case involving James P. Kleier, a prominent San Francisco attorney who pleaded guilty to failing to file a tax return. On June 18, Magistrate Judge Laurel Beeler of the US District Court for the Northern District of California, sentenced Kleier to 12 months in prison as […]

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One June 9, the Supreme Court of the United States decided that it would not review a ruling from the Eighth Circuit Court of Appeals involving Wells Fargo and the economic substance doctrine. Earlier this year, the Eighth Circuit affirmed the IRS’s disallowance of a $423 million capital loss claimed by a Wells Fargo subsidiary […]

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In a victory for taxpayers and a blow to the Internal Revenue Service’s (IRS’s) summons powers, the Supreme Court of the United States ruled that the target of an IRS summons is entitled to an evidentiary hearing to argue that the summons was improperly issued. The case at hand involves Michael Clarke, an investor from […]

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According to one Internal Revenue Service (IRS) official, the agency will soon begin reviewing all taxpayer certifications of non-willful noncompliance that it receives through the new streamlined filing compliance procedure set up for US taxpayers with undeclared overseas accounts. During the June 20 New York University School of Continuing and Professional Studies tax controversy conference, […]

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