Month: November 2015

It’s not uncommon for attorneys to push attorney – client privilege as a foolproof system that lets their clients say whatever they want. However, as with so many other things, attorney – client privilege isn’t entirely black and white. Previously, we’ve written about how Sovereign Management …

Previously, I’ve written how business partners can use the tax code to attempt to, not – so delicately, “screw” a business partner. Thanks to some terrific research by Farley P. Katz, Joseph Perera, and Katy David at Strasburger & Price LLP, it seems, unfortunately, that even more …

A recent tax court case had many of us excited about the government losing an FBAR penalty case and the impact it could have for taxpayers. Unfortunately, upon further review, while the taxpayer deserves congratulations for his impressive and complete win, this particular case was limited in…

  In this episode of our podcast, Parental Advisory, we discuss the advantages and disadvantages of the curious tax procedure know as an IRS private letter ruling.     What is a private letter ruling?   A taxpayer requested private letter ruling (PLR), per the IRS, is "a written statement issued to a taxpayer that interprets and … Read more

UPDATE 11/24/2015: Privatbank IHAG Zürich AG (IHAG) has also reached a resolution under the department’s Swiss Bank Program. If our posts feel a little bit like déjà vu, there may be a reason. On Tuesday, we wrote how the IRS had added three more Swiss banks to the Foreign Bank …

Understanding the Streamlined Offshore Disclosure Program – Video and accompanying transcript.

The Treasury Inspector General for Tax Administration released a report, and of particular concern is the indication that the IRS has been targeting a certain class of tax offenders.

Since our last update on the “blacklisted” Swiss banks, a handful more have been added to the IRS Foreign Financial Institution List, including:

Banque Internationale a Luxembourg (Suisse) SA (effective 11/12/15)
Zuger Kantonalbank (effective 11/12/15)
Standard Chartered Bank …