Private Equity Guru Smith Got a Hell of a Deal

 Thursday, October 29, 2020

Court of Appeals Finds No Harm Attorney's Failure to Assure Client Understood Relevant Conduct for Sentencing Loss Calculations 

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In Jones v. United States , 2020 U.S. App. LEXIS 33857 (6th Cir. 2020), unpublished, here , the Court by Order denied Jones’ request for a c...

Saturday, October 24, 2020

Fourth Circuit Affirms District Court Decision in Tax Crimes Case to Limit Taxpayer's Reading Excerpts From Book on Cheek Willfulness Issue 

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In United States v. Gerard , 2020 U.S. App. LEXIS 33341 (4th Circuit 10/22/20), here and govinfo here , the Court affirmed the taxpayer’s c...

Corporate Taxpayer (AIG) "Settles" Tax Shelter Litigation Admitting Tax Shelters Were Shams 

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The SDNY U.S. Attorney (Acting) issued this stunning press release yesterday:  Acting Manhattan U.S. Attorney Announces Settlement Of Tax Sh...

Friday, October 23, 2020

Private Equity Guru Smith Got a Hell of a Deal 

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Today, the Wall Street Journal published what, I understand, is called an “explainer” about the Brockman indictment and the Smith nonprosecu...

Wednesday, October 21, 2020

Fourth Circuit Holds Taxpayer Liable for Willful FBAR Penalty 

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In United States v. Horowitz , ___ F.3d ___, 2020 U.S. App. LEXIS 33074 (4th Cir. 2020), here , the Fourth Circuit held that the taxpayer, w...

VITAMIN D UPDATE:  More than 80 per cent of hospitalized COVID-19 patients had vitamin D deficiency. “For the study, the 216 hospitalized patients’ vitamin D levels were compared to those of a control group of 197 people of similar age and sex from a population-based cohort in the same geographical area. . . .

Like a 'criminal syndicate': eight charged in Chinese harassment plot

Tax administration and reform within the digitalised economy is an ongoing global debate. In the study, the global tax response to various elements introduced by the digitalisation of the economy is synthesised, analysed and evaluated. The study is set apart from other studies, as it provides a global and holistic overview of current tax reform of all major tax types impacted by the digitalisation of the economy. The study’s results are based on evidence collected for 120 countries worldwide and reflect that while the digitalised economy is regarded as borderless and digitalised, current international responses remain influenced by country borders and traditional tax principles that have led to global tax reform that is complex, expensive and difficult for highly digitalised multinational entities to comply with. 

An evaluation of the legislative and policy response of tax authorities to the digitalisation of the economy