by Phil Hodgen, Hodgen Law Group PC on November 18, 2009
Not that you’d care (most of you, anyway) but UBS has information about The Troubles on its own website. All prose on www.ubs.com was heavily sedated prior to publication.
Nevertheless, the linked page may be marginally useful to you. I personally find it as a useful site to pull down some of the basic [...]
by Phil Hodgen, Hodgen Law Group PC on November 18, 2009
If you’re in the pipeline with a voluntary disclosure, you are facing a January 15, 2010 deadline. That is the date by which you have to get the “essay answers” so-called optional letter (warning: Word file) in at Criminal Investigations.
We are proactively bugging all of our clients to get this work done, whether [...]
by Phil Hodgen, Hodgen Law Group PC on November 18, 2009
I’ve posted the full text of the agreement between UBS and the IRS over at my main website. Go there to read it. I will dissect it and post some commentary in a separate blog post.
by Phil Hodgen, Hodgen Law Group PC on November 17, 2009
The information is trickling out about the criteria used to select UBS customers for revelation to the IRS. See Jack Townsend’s post, with links and the usual helpful commentary. The criteria largely follow what I blogged before, but with additional detail.
by Phil Hodgen, Hodgen Law Group PC on November 9, 2009
I’ve posted an email from a person in the voluntary disclosure program on the main website. Go take a read.
This person, Sandra Brown, is one of your 7,500 felons. (cf. her comment at the UCLA Extension Tax Controversy program in October. Look at Jack Townsend’s point number 3. I was sitting [...]
by Phil Hodgen, Hodgen Law Group PC on November 6, 2009
Thanks to someone who will remain nameless, here is an article showing the criteria by which the IRS queried UBS for names of American customers:
In German
The Google Translate version follows:
SWITZERLAND SACRIFICE UBS CLIENTS
The American tax authorities are not only the data from UBS tell customers, but also those of the participating Swiss asset manager. [...]
by Phil Hodgen, Hodgen Law Group PC on November 5, 2009
Heh.
The IRS seems to be writing the rules as they go along in the foreign bank account amnesty program, AKA the voluntary disclosure program.
The first step in the process is to get processed through IRS Criminal Investigations.
When Criminal Investigations decides you are boring, you get a letter (example here). The letter [...]
by Phil Hodgen, Hodgen Law Group PC on November 5, 2009
We have some voluntary disclosure of bank account cases at the end of the road — the civil audit. We don’t have any that have actually closed yet.
Now I know why. The IRS doesn’t have the paperwork done yet to actually close an amnesty case.
The paperwork needed is colloquially called a [...]
