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Bank Swiss Program

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 – 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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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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Standard Chartered to pay $6.3m in U.S., Swiss program deal

Standard Chartered to pay $6.3m in U.S., Swiss program deal

(Reuters) – Standard Chartered Bank’s Swiss unit will pay a $6.3 million penalty as part of a deal it reached with the U.S. Justice Department to avoid possible prosecution for helping Americans evade taxes, the department said on Friday. The bank also agreed to cooperate in any criminal or civil proceedings involving U.S. accounts and […]

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BBVA Suiza S.A. to pay more than $10 million under U.S. Swiss bank program

BBVA Suiza S.A. to pay more than $10 million under U.S. Swiss bank program

WASHINGTON (Reuters) – BBVA Suiza S.A. will pay more than $10 million and continue to cooperate with American authorities in a resolution reached under the Swiss Bank Program, the U.S. Justice Department said on Friday. “Swiss banks such as BBVA Suiza S.A. are providing detailed information regarding their efforts to conceal U.S.-related accounts, and are […]

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Credit Suisse granted exemption to continue U.S. pension business

Credit Suisse granted exemption to continue U.S. pension business

NEW YORK (Reuters) – The U.S. Department of Labor on Thursday said it granted Credit Suisse Group AG an exemption from certain restrictions stemming from its guilty plea to helping Americans evade taxes, effectively allowing the bank to continue to manage $2 billion in U.S. retirement money. The Zurich-based bank can keep managing U.S. pension […]

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Two more Swiss banks strike deals with U.S. over tax evasion

Two more Swiss banks strike deals with U.S. over tax evasion

WASHINGTON (Reuters) – Two more Swiss banks will pay penalties to the United States as part of settlements that mean they will not face criminal charges for helping Americans avoid taxes, U.S. authorities said on Thursday. SB Saanen Bank AG will pay nearly $1.4 million and Privatbank Bellerive AG will pay $57,000, the U.S. Justice […]

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Washington Alert – GAO report on budget; DOJ and 2 more Swiss banks; TIGTA faults IRS on advising taxpayers on minimum distribution rules on IRAs

Washington Alert – GAO report on budget; DOJ and 2 more Swiss banks; TIGTA faults IRS on advising taxpayers on minimum distribution rules on IRAs

Faced with ongoing budget constraints, IRS has been scaling back various activities and demonstrating flexibility in absorbing cuts in funding, the Government Accountability Office (GAO) said in a report released on July 24. (GAO-15-624) IRS’s total appropriations hit a high of $12.1 billion in fiscal year (FY) 2011 but declined to $11.3 billion in FY […]

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Two more Swiss banks strike deals with U.S. over tax evasion

Two more Swiss banks strike deals with U.S. over tax evasion

WASHINGTON (Reuters) – Two more Swiss banks will pay penalties to the United States as part of settlements that mean they will not face criminal charges for helping Americans avoid taxes, U.S. authorities said on Thursday. SB Saanen Bank AG will pay nearly $1.4 million and Privatbank Bellerive AG will pay $57,000, the U.S. Justice Department […]

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Washington Alert – APTC face spotlight; TIGTA on IRS Automated Underreporter Program; 3 More Banks enter Swiss Bank Program

Washington Alert – APTC face spotlight; TIGTA on IRS Automated Underreporter Program; 3 More Banks enter Swiss Bank Program

The use of the advance premium tax credit (APTC) provided for by the Affordable Care Act and the administration of the tax credit are now in the spotlight of Sen. Orrin Hatch (R-UT), chairman of the Senate Finance Committee. During July 16 testimony before Hatch’s panel, the Government Accountability Office (GAO) revealed it had conducted […]

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Washington Alert – Privatbank Von Graffenried AG enters Swiss Bank Program; TIGTA finds IRS did not have controls to stop contracts to companies that owe federal taxes and/or are felons; Tax Policy Center paper on”Financial Transaction Taxes in Theory and Practice”

Washington Alert – Privatbank Von Graffenried AG enters Swiss Bank Program; TIGTA finds IRS did not have controls to stop contracts to companies that owe federal taxes and/or are felons; Tax Policy Center paper on”Financial Transaction Taxes in Theory and Practice”

The Justice Department (DOJ) announced on July 2 that Privatbank Von Graffenried AG, which is based in Bern, reached a resolution under the department’s Swiss Bank Program. As part of the non-prosecution agreement with DOJ, the bank agreed to pay a penalty of only $287,000. The bank’s problems with U.S. authorities stemmed from the activities […]

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Julius Baer to take $350 million charge as end to U.S. tax probe nears

Julius Baer to take $350 million charge as end to U.S. tax probe nears

ZURICH (Reuters) – Julius Baer said on Tuesday it would book $350 million against first-half results towards an expected settlement in a U.S. criminal investigation into how the Swiss bank helped wealthy Americans dodge taxes. The provision is far less than what most analysts had expected, with some estimates as high as 850 million Swiss […]

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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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Member CA Bar Member Orange County Bar US Tax Court Attorney