The amnesty process is broken but can be fixed

by Phil Hodgen, Hodgen Law Group PC on February 5, 2010

Those of you reading this know that the Voluntary Disclosure Program for people with undisclosed foreign bank accounts is a broken and malignant process. I’ve posted a lengthy post arguing the Voluntary Disclosure Program is off the rails, with a suggestion for how the IRS might make lemonade from its lemons.

As always, comments welcome, and keep reading. I’m putting most of my new stuff on the main site now. It’s simpler than having a bunch of satellite websites.

Happy Friday from rainy Southern California.

/Phil

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Please go to main blog for more info

by Phil Hodgen, Hodgen Law Group PC on February 2, 2010

I’ve been posting a lot of information over at my main blog, http://hodgen.com/phils-blog. I’m pulling everything together in one main site rather than spreading myself all over the interwebz.

Yeah, and the Germans are buying stolen property again. This time, watch out you people with accounts at Credit Suisse.

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Digging deeper into the prosecution of offshore account cases

January 22, 2010

Tax Notes Today has an article (2010 TNT 13-6) reporting on a Federal Bar Association Tax Section meeting on January 20, 2010, attended by practitioners and government folk. Key points that jumped out at me:
Small number of criminal prosecutions (so far)
There are approximately 150 Department of Justice investigations from the UBS situation, and about [...]

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Another Swiss banker planning to spill the beans

January 22, 2010

Rudolf Elmer. He’s a former Swiss banker, worked for Bank Julius Baer. Leaked a bunch of documents to www.wikileaks.org. Now planning to go have a chat with the German tax authorities and spill a few more beans. From the article:
[Rudolf Elmer] said that he would fly on Tuesday to Düsseldorf, Germany, [...]

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The IRS adds two more FAQs to its FAQs

January 12, 2010

The IRS has added two more questions and answers to the Voluntary Disclosure Program FAQs on its website. They were added January 8, 2010.
Here are the questions for your reading pleasure. There is a quiz at the end of class today.
Questions and answers 53 and 54 were added January 8, 2010.
Q 53. [...]

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New post on latest Swiss court ruling on UBS name disclosures

January 12, 2010

Yeah the Swiss courts said “Silly bureaucrats, you shouldn’t have violated Swiss banking laws when you gave names to the IRS.” Latest post on this over at the main blog.
Chum. Two hundred fifty human pieces of chum.

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Optional format letter for amnesty is due January 15, 2010

January 11, 2010

For all of you out there who are in the amnesty program for undisclosed offshore accounts, there is a deadline — this Friday. You have to get your second letter to Criminal Investigations by this Friday or the IRS will kick you out of the program.
The letter you have to submit is [...]

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Italians have their own offshore account amnesty

December 16, 2009

The Economist has a short article about the ongoing Italian offshore account amnesty. Look carefully for the penalty: Five. Percent.
ITALIANS are reckoned to have around €300 billion ($440 billion) of assets stashed abroad. The government would like to lure them back, or at least recoup some of the taxes it has lost [...]

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New post on the latest theft of bank data

December 14, 2009

I’ve posted on the main site about the theft of client data from HSBC in Geneva. This one is aimed at French customers of HSBC.
Secrecy is a doomed tax strategy. It may be now, or it may be later. But sooner or later secrecy will fail you. (Or if [...]

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The new Information Document Request — Form 4564

December 14, 2009

I’ve posted a PDF version of the new Information Document Request over at hodgen.com. For those of you in the program, this is what you have to look forward to.

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