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Department of Justice

National Bank of Panama to consider request to open New York branch

National Bank of Panama to consider request to open New York branch

PANAMA CITY (Reuters) – The National Bank of Panama (Banconal) said on Monday it will consider a proposal to open a correspondent bank in New York, a move that could help the country’s financial sector, which has come under close scrutiny due to the Panama Papers scandal. Rolando de Leon de Alba, general manager of […]

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Journalists will not share Panama Papers with U.S. Justice Dept

Journalists will not share Panama Papers with U.S. Justice Dept

WASHINGTON (Reuters) – The media group that coordinated the Panama Papers investigation into offshore companies said on Thursday it would not participate in a criminal probe by the U.S. Department of Justice. Preet Bharara, the U.S. Attorney for Manhattan, wrote to the International Consortium of Investigative Journalists seeking additional information from the group to aid his investigation […]

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Mo Money Tax Return Preparers Plead Guilty to Conspiracy to Defraud the United States and Filing False Tax Returns

Mo Money Tax Return Preparers Plead Guilty to Conspiracy to Defraud the United States and Filing False Tax Returns

According to the Department of Justice Press Release: Two tax return preparers pleaded guilty to one count of conspiracy to defraud the United States and one count of aiding and assisting in the preparation of a false tax return, announced Acting Assistant Attorney General Caroline D. Ciraolo of the Justice Department’s Tax Division and U.S. […]

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U.S. Justice Dept reviewing Panama documents

U.S. Justice Dept reviewing Panama documents

WASHINGTON (Reuters) – The U.S. Justice Department is reviewing the leaked documents from a Panamanian law firm that reveal the offshore financial arrangements of global politicians and public figures, a department spokesman said on Monday. The department is determining whether the documents point to evidence of corruption and other violations of U.S. law. “The U.S. […]

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U.S. charges consultant to Iran’s UN mission-hearing

U.S. charges consultant to Iran’s UN mission-hearing

NEW YORK (Reuters) – U.S. prosecutors on Wednesday unveiled criminal charges at a Brooklyn, New York, court hearing against a consultant to the Iranian mission to the United Nations. Ahmad Sheikhzadeh, 60, is accused of charges related to sanctions violations, money laundering and tax matters, his lawyer, Steve Zissou, said at the hearing. Sheikhzadeh had pleaded not […]

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Washington Alert – Cayman companies plead guilty; Income tax refunds await; TIGTA report on over-aged correspondence and taxpayer burden

Washington Alert – Cayman companies plead guilty; Income tax refunds await; TIGTA report on over-aged correspondence and taxpayer burden

In a case marking the first time non-Swiss financial institutions have been convicted of conspiring to facilitate federal tax evasion, two Cayman Island financial institutions pleaded guilty in federal court to conspiring with U.S. taxpayer-clients to hide more than $130 million in offshore accounts and evade U.S. taxes, the Justice Department (DOJ) announced on March […]

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U.S. man accused of using Craigslist to find fake tax dependents

U.S. man accused of using Craigslist to find fake tax dependents

KANSAS CITY, Mo. (Reuters) – A Missouri man has been charged with filing false U.S. tax returns after allegedly using Craigslist to find three children he could falsely claim as dependents, a federal prosecutor announced on Wednesday. A U.S. grand jury in Springfield, Mo., indicted Raheem McClain, 37, of Ozark, Missouri, on three counts of […]

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Cayman National units admit helping U.S. clients evade taxes

Cayman National units admit helping U.S. clients evade taxes

NEW YORK (Reuters) – Two units of Cayman National Corporation Ltd pleaded guilty to U.S. charges on Wednesday as part of a $6 million settlement of an investigation into how the financial services firm helped Americans evade paying taxes.  Click here for the link to the Department of Justice Press Release. Cayman National Securities Ltd […]

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U.S.-Swiss treaty prevented court from considering taxpayer’s refund claim

U.S.-Swiss treaty prevented court from considering taxpayer’s refund claim

Starr International Company, Inc., (DC Dist Col 2/2/2016) 117 AFTR 2d ¶ 2016-396 A district court held that the terms of the U.S.-Swiss tax treaty caused the court to “lack the power” to rule on a Swiss-domiciled corporation’s U.S income tax refund claim. The holding effectively reversed a previous holding of the court on this […]

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Washington Alert – DOJ files criminal charges against Bank Julius Baer & Co., Ltd; CBO report on estimated budget deficit of $165 billion; TIGTA report on IRS’s Return Review Program (RRP)

Washington Alert – DOJ files criminal charges against Bank Julius Baer & Co., Ltd; CBO report on estimated budget deficit of $165 billion; TIGTA report on IRS’s Return Review Program (RRP)

The Justice Department (DOJ) on Feb. 4 announced that it has filed criminal charges against Bank Julius Baer & Co., Ltd., a Swiss financial institution, and also entered a deferred prosecution agreement that requires a payment by the bank of $547 million by Feb. 9. As described by DOJ, “Julius Baer is charged with conspiring […]

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Julius Baer settling U.S. tax case, ex-bankers to plead guilty

Julius Baer settling U.S. tax case, ex-bankers to plead guilty

NEW YORK (Reuters) – Two former Julius Baer bankers are expected to plead guilty on Thursday for helping wealthy American clients evade taxes as U.S. prosecutors unveil a $547 million settlement with the Swiss bank, a person familiar with the matter said. Daniela Casadei and Fabio Frazzetto, former client advisers at Julius Baer, are expected […]

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Washington Alert – DOJ continues foreign tax evaders; IRS webinar on changes in retirement plans; Advance Pricing and Mutual Agreement office (APMA) will begin accepting requests for bilateral advance pricing agreements (APAs) between the U.S. and India

Washington Alert – DOJ continues foreign tax evaders; IRS webinar on changes in retirement plans; Advance Pricing and Mutual Agreement office (APMA) will begin accepting requests for bilateral advance pricing agreements (APAs) between the U.S. and India

There will be no letup in the federal government’s ongoing campaign targeting U.S. taxpayers who hide foreign accounts and attempt to evade U.S. tax obligations, a key Justice Department (DOJ) official said on Jan. 29. In 2016, tax professionals will see “additional civil enforcement actions and ongoing and new criminal investigations and prosecutions,” Caroline Ciraolo, […]

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Washington Alert – Swiss Bank Program & HSZH Verwaltungs AG , GAO faults SB/SE audits, IRS issues refunds fast

Washington Alert – Swiss Bank Program & HSZH Verwaltungs AG , GAO faults SB/SE audits, IRS issues refunds fast

The Justice Department (DOJ) announced on Jan. 27 that it had reached its final non-prosecution agreement under the so-called Category 2 component of the Swiss Bank Program. HSZH Verwaltungs AG reached a resolution that requires the bank to pay a penalty of $49.8 million. Since last March, when the first non-prosecution agreement was made public, […]

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Washington Alert – Another Bank enters the Swiss Bank Program; CBO report on the budget; IRS issues reminder to non-credentialed tax preparers

Washington Alert – Another Bank enters the Swiss Bank Program; CBO report on the budget; IRS issues reminder to non-credentialed tax preparers

The Justice Department (DOJ) announced on Jan. 6 that Union Bancaire Privée, UBP SA (UBP) reached a resolution under the department’s Swiss Bank Program and agreed to pay a penalty of nearly $188 million. According to DOJ, the bank had a decades-long history of aiding and assisting U.S. clients in opening and maintaining undeclared accounts […]

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Washington Alert – DOJ & 2 more banks enter deal; Webinar on practicing before IRS; TIGTA report on further review needed to avoid questionable refunds

Washington Alert – DOJ & 2 more banks enter deal; Webinar on practicing before IRS; TIGTA report on further review needed to avoid questionable refunds

The Justice Department (DOJ) announced on Dec. 31 that two additional Swiss banks have reached resolutions under the department’s Swiss Bank Program which provides a path for Swiss banks to resolve potential criminal liabilities in the U.S. Bank Lombard Odier & Co. Ltd. will pay a penalty of $99.8 million, and DZ Privatbank (Schweiz) AG […]

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Swiss banks to pay $178 million in latest U.S. Justice Dept settlements

Swiss banks to pay $178 million in latest U.S. Justice Dept settlements

(Reuters) – Four Swiss banks will pay a total of more than $178 million to the U.S. Department of Justice to avoid possible prosecution for helping Americans evade taxes, the department said on Wednesday. The Justice Department has now reached agreements with 75 Swiss banks under a voluntary program it launched in 2013 to allow […]

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Washington Alert – DOJ Penalties under the Swiss Bank Program; IRS Return Preparer Office issues warning letters; IRS urges use of Get Transcripts program

Washington Alert – DOJ Penalties under the Swiss Bank Program; IRS Return Preparer Office issues warning letters; IRS urges use of Get Transcripts program

The Justice Department’s (DOJ’s) Tax Division capped off a whirlwind period of Swiss Bank Program-related activity ending on Dec. 23 with the last of its announcements revealing details of resolutions generating penalties totaling more than $280 million. As described by DOJ, the Swiss Bank Program, which was launched in August 2013, provides a path for […]

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Swiss banks to pay $130 mln, avoid charges on aiding U.S. tax evasion

Swiss banks to pay $130 mln, avoid charges on aiding U.S. tax evasion

(Reuters) – Three Swiss banks, including a unit of France’s Crédit Agricole SA, will pay a total of more than $130 million to the U.S. Justice Department to avoid possible prosecution for helping Americans evade taxes, the department said on Tuesday. The Zurich-based unit of Crédit Agricole will pay $99.2 million, the largest share of […]

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Treasury Department publishes list of boycott countries

Treasury Department publishes list of boycott countries

Department of the Treasury: List of Countries Requiring Cooperation With an International Boycott (Oct. 22, 2015). The U.S. Treasury Department (Treasury) has published a current list of countries that may require participation in, or cooperation with, an international boycott for purposes of Code Sec. 999—the rule that denies certain tax benefits to a person that […]

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Swiss banks to pay $81 million, avoid U.S. charges on aiding tax evasion

Swiss banks to pay $81 million, avoid U.S. charges on aiding tax evasion

(Reuters) – Three Swiss banks will pay a total of more than $81 million to the U.S. Justice Department to avoid possible prosecution for helping Americans to evade taxes, the department said on Thursday. The three banks, the Swiss unit of BNP Paribas SA; KBL (Switzerland) Ltd; and Bank CIC, also agreed to cooperate in […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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