New Development in Offshore Tax Enforcement — UBS and Justice Department Agree on Major Issues
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...
UBS Client Pleads Guilty to Filing False Tax Returns for Failure to Report Swiss Bank Accounts
Offshore Tax Evasion by UBS Client
IRS Collection Update — Health Savings Accounts are Subject to Federal Tax Levy
In a recently issued Chief Counsel Advice (CCA 200927019), the IRS stated that it can issue a levy on a taxpayer’s health savings account (HSA). What is even more interesting, in such a case, the taxpayer will be liable for a 10% excise tax on an HSA...
Employment Taxes and the Trust Fund Recovery Penalty (TFRP)
In order to protect payment of withheld income and employment taxes, including social security taxes, railroad retirement taxes, or collected excise taxes, Congress passed a law that provides for the Trust Fund Recovery Penalty (“TFRP”). These taxes are called trust...