Tax Lawyer's Blog

AIG wants to sell one if it’s subsidiaries, the American Life Insurance Company (”ALICO”), to MetLife but will first have to get a private letter ruling from the IRS.
Here’s the New York Times’ Mary Williams Walsh and Michael J. de la Merced:
AIG announced almost a year ago that it would sell… ALICO, to raise about $9 billion [...]

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If the UBS scandal didn’t convince you that the Obama administration is going whole hog after U.S. taxpayers with offshore bank accounts, perhaps a recent article written by Dean Mark Mason for Taxes, The Tax Magazine will.
The piece is titled Foreign Bank Accounts – FBAR Reporting Obligations, Enforcement Exposures and Managing the Risk: What Every Tax and [...]

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WebCPA reports that Switzerland’s Federal Administrative Court has ruled that the agreement between Switzerland and the US requiring UBS to disclose the names of more than 4,000 American taxpayer investors violates Swiss bank secrecy laws:
The ruling last Friday on 26 sets of bank accounts threatens a deal that the Swiss and U.S. governments hammered out last August after [...]

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Professor Paul Caron reports that Tax Analysts have named the Tax Person of 2009:
Tax Analysts has named its Tax Person of the Year:  Bradley Birkenfeld, the whistleblower in the UBS offshore tax shelter case:
Birkenfeld must be considered among the biggest whistle-blowers of all time. He is the Benedict Arnold of the private banking industry and single-handedly made [...]

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Yesterday, IRS Commissioner Doug Shulman spoke at the 22nd Annual George Washington International Tax Conference.  He discussed a broad range of issues from transfer pricing to the use of hybrid structures in international tax planning. However, what I found most interesting were his comments on the landmark UBS settlement and the recent offshore voluntary disclosure program.
1.  IRS is [...]

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The Washington Post reports that the the criteria the United States and Swiss governments used to determine which American UBS customers names were disclosed to the IRS has been made public:
If you had less than $248,200 (250,000 Swiss francs) in your secret account at Switzerland’s largest bank, or if it generated less than $99,280 (100,000 Swiss francs) [...]

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The New York Times reports that the German government has been rebuked by it’s Council of Wise Men for promising tax cuts without proposing corresponding spending cuts:
The German government drew sharp criticism Friday from its economic council of experts for neglecting the budget deficit and focusing instead on tax cuts, which the experts said would fail to [...]

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Switzerland? No.
Monaco? Nope.
Belize? No sir.
Here it is straight from the mouth of the Cato Institute:
Tax competition is an issue that arouses passion on both sides of the debate. Libertarians and other free-market advocates welcome tax competition as a way of restraining the greed of politicians. Governments have lowered tax rates in recent decades, for instance, because [...]

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The Associated Press reports that the IRS will extend the September 23rd deadline for foreign tax evaders to file for amnesty. The new deadline will be October 15th:
The IRS is extending the Wednesday deadline for international tax dodgers to apply for an amnesty program in order to give a rush of applicants more time to prepare their [...]

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The Wall Street Journal reports that the United States has entered into a tax information sharing agreement with Monaco.
Here’s the entire post:
“We are working with countries like Monaco to ensure that the IRS has access to the information that it needs to enforce U.S. tax law,” Deputy Treasury Secretary Neil Wolin said in a statement.
Under the [...]

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