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.

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.

Holtz, Slavett & Drabkin, APLC is proud to sponsor the 26th Annual UCLA Tax Controversy Institute, which will take place on October 26, 2010, at the Beverly Hills Hotel.

In a recent case of United States v. J. Bryan Williams, the U.S. District Court for the Eastern District of Virginia found that the government had failed to meet its burden to establish by a preponderance of the evidence that a taxpayer willfully failed to report his interest in a foreign bank accounts that were omitted from the individual’s 2000 tax return.

On July15, 2010, Switzerland’s Federal Administrative Court rejected a UBS account holder’s complaint that sought to prevent the release of her client information to the U.S. tax authorities. The ruling is significant because it signals the likely end-game for UBS account holders with undisclosed accounts who had sought to prevent their account information from being delivered to the IRS.

On June 17, 2010, Swiss Parliament approved a Swiss-U.S. tax agreement that requires UBS AG to provide information to the IRS on 4,450 U.S. persons with undisclosed accounts at the Swiss bank.

In 2008, the California State Board of Equalization initiated a program to increase prosecution of violations California Revenue and Tax Code section 6071 (engaging in a sales business without a valid California seller’s permit).  If you received BOE-420-R Letter, Notice to Appear, then the State Board of Equalization has determined tha t you are conducting sales [...]

The United States government has been pressing UBS AG, one of the Switzerland’s largest banks, to release the names of a reported 52,000 wealthy Americans with accounts at the bank. Federal authorities suspect that some U.S. taxpayers may be using accounts at UBS to evade taxes. A civil case brought by the United States against [...]