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Abusive Tax Shelters

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Top Ten Tax Enforcement Actions of 2022

Posted  02/8/23
us cash with "taxes" sign on top
Tax fraud can take many forms, but each form results in shortchanging government coffers.  More seriously, with our tax system depending heavily on taxpayers’ willingness to voluntarily file tax returns and pay taxes, tax fraud undermines confidence in the system.  Enforcement of tax laws builds confidence in the system, and deserves to be a law enforcement priority. The top tax recoveries in 2022 start with...

Top Ten Tax Recoveries for 2021

Posted  01/19/22
Currency Zoomed In
Our top tax recoveries for 2021 total over $7 billion, an impressive number that is due largely to just one of our top ten tax recoveries. Tax evaders were creative last year, utilizing offshore banking, good old tax fraud, and forum shopping for an accounting opinion that fits—all with the intention of cheating the IRS and, in return, the taxpaying public. IRS Criminal Investigation flexed its muscles and went...

December 20, 2021

James Tarpey, an attorney and principal in Project Philanthropy Inc. dba Donate for Cause (DFC), has been ordered to pay $8.5 million in penalties for promoting a tax shelter with claims that timeshare owners could donate their unwanted timeshare interests to DFC and receive tax benefits in return.  Tarpey and his agents prepared appraisals on donated timeshares, despite lacking sufficient independence and knowing that his false appraisals resulted in tax avoidance.  DOJ

Pandora Papers Show the Value of Financial Transparency, the Critical Role of Whistleblowers – and the Need for Additional Regulation

Posted  10/8/21
This week, the International Consortium of Investigative Journalists and its partners began publicly reporting on the “Pandora Papers,” a trove of millions of leaked documents from firms around the world that help customers set up “offshore” accounts and shell companies designed to conceal financial truths.  The leaked documents, and the extensive reporting on the documents, sheds light on the murky world of...

August 3, 2021

Bermuda bank Bank of N.T. Butterfield & Son Limited will pay $5.6 million and enter into a deferred prosecution agreement to resolve charges that between 2001 and 2013 it assisted U.S.-taxpayer clients in opening and maintaining undeclared foreign bank accounts.  The bank has provided the government with approximately 386 unredacted client files.  USAO SDNY; IRS

May 14, 2021

Swiss insurance company Swiss Life Holding AG and related entities will pay $77 million and enter into a deferred prosecution agreement admitting that they conspired with U.S. taxpayers to  conceal more than $1.452 billion in assets and income in offshore insurance policies and related policy investment accounts.  From 2005 to 2014, Swiss Life maintained approximately 1,608 Private Placement Life Insurance policies known as “insurance wrappers,” with associated policy investment accounts with Swiss Life entities identified as the owner, allowing U.S. taxpayers to hide undeclared assets and income and evade taxes.  Beginning in 2008, Swiss Life specifically marketed such policies to taxpayers withdrawing assets from UBS and other Swiss banks in response to offshore tax enforcement efforts aimed at those bank.  DOJ; USAO SDNY

Want to Fix the Trillion Dollar Tax Gap? How Whistleblowers Can Help

Posted  04/23/21
Earlier this month, Internal Revenue Service Commissioner Charles P. Rettig testified before the Senate Finance Committee, addressing the 2021 filing season and the “21st Century IRS.”  At the hearing, Committee Chairman Ron Wyden (D-OR) raised the topic of the tax gap, referring to the difference between the total taxes that are legally owed, and the total taxes that are paid by individuals and entities. ...

March 11, 2021

Swiss bank Rahn+Bodmer Co. will pay $22 million to resolve allegations that it conspired with U.S. customers to evade their U.S. tax obligations by concealing their ownership and control of up to $550 million in undeclared funds held in R+B accounts.  The bank entered into a deferred prosecution agreement and will cooperate with further investigations, including of U.S. accountholders.  DOJ

Top Ten Tax Recoveries of 2020

Posted  02/5/21
us cash with "taxes" sign on top
Tax fraud and tax evasion, unfortunately, continued apace last year.  Yet even in the face of waning tax resources, enforcement authorities chalked up some key wins in 2020. Criminal recoveries tend to dominate the headlines because many of the biggest tax recoveries are not public: the IRS scrupulously protects taxpayer privacy, and no announcements are made for civil tax recoveries.  Thus only those that result...

Sunshine State Local Elections Shine Light on How Dark Shell Company Data Can Be

Posted  11/18/20
By Sarah “Poppy” Alexander
top-secret-seal
Amidst the ongoing saga of the US national elections, Florida local elections may not have made much of a ripple.  But one small scandal in the Sunshine State reveals a lot about the ongoing problem the US has with shell corporations and their hidden ownership structures. The story is convoluted, as most shell company stories are.  A political donor, Proclivity, who had never donated money in Florida before,...
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