Tag Archives: UBS

IRS Criminal Division Announces 2010 Investigation Targets

The IRS has announced its Criminal Investigation Annual Business Plan for FY2010. This year’s plan is part of the IRS’ larger 5 year strategic plan for 2009 - 2013. Those of us who are baby boomers remember the then Soviet Union’s “5 year plans.” Like the IRS strategic plan, those plans were big on

UBS Redux - Intentional Leak or Accident?

by Brian Mahany
As part of the litigation settlement between Swiss bank UBS and the U.S. Treasury, UBS promised to turn over 4,450 names to the IRS.  The process involved turning over the names to Swiss authorities who would then forward them to the IRS.  But in a strange move, UBS sent thousands of letters to

FBARs or Prison Bars?

by Brian Mahany
The federal amnesty deadline for declaring foreign accounts to the IRS expired October 15th. After the highly publicized legal action against Swiss bank UBS began, the IRS offered an amnesty to Americans with assets in foreign accounts.  According to federal money laundering laws and IRS regulations, businesses and individuals holding more than $10,000

Get to Us Before We Get to You

“The real things to know is that folks will stand to lose more than they will to win.” Pug Pearson on poker.
The IRS has invited all 52,000  Americans that maintain secret accounts at UBS to a game of poker. Ditto Americans with accounts in other Swiss and foreign banks such as Credit Suisse.  What happens

Let’s Make A Deal - the Swiss Dept. of Justice & Police Edition

Let’s Make A Deal - the Swiss Dept. of Justice & Police Edition by Brian Mahany (www.mahanylaw.com)
Tax attorneys, privacy advocates and the asset protection professionals have been closely watching the litigation between the United States and Swiss bank, UBS. The case started when the IRS sought the identities of U.S. taxpayers behind 52,000 secret accounts

Is Investing Offshore Still Legal?

Is investing offshore still legal? The simple answer is “Of course.”  Since the UBS mess earlier this year, many people have questioned whether offshore investment remains legal.
Investing offshore or creating offshore structures such as trusts or international business corporations is completely legal.  What gets people in trouble, however, is failing to report accounts to the