Oldest Swiss Bank Indicted for Tax Fraud

We are proud to announce that all three founding members of our tax law firm — David Holtz, Gary Slavett and Igor Drabkin — were selected as 2012 Southern California Super Lawyers in Tax Law.

Two Holtz, Slavett & Drabkin tax law partners, Gary Slavett and Igor Drabkin, were featured today by CNN’s Erin Burnett OutFront program regarding Mitt Romney’s tax returns released this morning.

In the recently issued Notice 2012-8, the IRS proposed a new Revenue Procedure that would revise the threshold requirements for requesting equitable innocent spouse relief. The proposed Revenue Procedure would revise the factors used by the IRS in evaluating requests for innocent spouse relief submitted under Code Sec. 6015(f) when the facts and circumstances warrant. The guidelines would ensure that, when appropriate, requests are granted in the initial stage of the administrative process.

The National Taxpayer Advocate (NTA) has issued a Taxpayer Advocate Directive , complaining about unfair treatment of certain participants in the 2009 Offshore Voluntary Disclosure Program (OVDP). It appears that the NTA shared the same frustration with the OVDP that many tax practitioners, including our tax attorneys, have felt over the infamous Q&A 35 published by the IRS in the Frequently Asked Questions and Answers for the 2009 program.

Today, the IRS announced that they reopened the Offshore Voluntary Disclosure Program for taxpayers with undeclared foreign accounts.

On January 3, 2012, the U.S. Attorney’s Office for the Southern District of New York charged three Swiss bankers with hiding more than $1.2 billion in U.S. taxpayer accounts from the IRS. The announcement was made by Preet Bharar, the Manhattan U.S. Attorney.

IRS has put in place a program aimed at auditing taxpayers who did a so called “quiet disclosure” — those who chose not to make a voluntary disclosure, but rather chose to quietly file amended tax returns and FBARs.

The Internal Revenue Service released details of its plan to show some leniency on the penalties for failure to file tax returns and Foreign Bank Account Reports for the American citizens living abroad.

Credit Suisse AG, the second largest bank of Switzerland, has notified some of its U.S. clients that it will disclose their identities and account details to the Internal Revenue Service.