Thursday, July 11, 2024

Swiss Bank Spins on Facilitating U.S. Tax Evasion

I'm Mike Moore, welcome to Frontline!  New leadership named in ATO restructure By Julian Bajkowski


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The International Sludge Academy, launched in 2023, is a partnership between the OECD and the Government of New South Wales (NSW) in Australia. Over the course of 5 months, 16 teams from 14 countries completed sludge audits on government processes and public services. Learn more about the Academy and the sludge audit approach in our previous blog: “Spotting the sludge: Behavioural audits to improve public services across countries.”


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Swiss Bank Spins on Facilitating U.S. Tax Evasion 

I link to a new posting summarizing one Swiss view of the Swiss-U.S. tax dispute. The power the US wields over the Swiss financial centre (Swissinfo.ch 5/22/24), here. The article emphasizes the U.S. political power that resulted in Swiss banks disclosing and paying the price for conspiring with U.S. taxpayers to evade their U.S. tax obligations. The latter activity was not forced on Swiss banks. They could have refused to participate (conspire with) the U.S. taxpayers. They did not so in order to earn more profits. They were called out and made to pay the piper. Not much sympathy there.

I guess the message is that, if the U.S. had not had such financial power, their assisting in U.S. tax cheating was OK.

Federal Tax Crimes Blog Total Pageviews Hit 10 Million + and Thoughts on Comments to Blogs 

I just noticed in the innards of this Federal Tax Crimes Blog that the blog has had over 10 million pageviews. I went into the design features and found a “gadget” that I added to the right-hand column with the total pageviews which, as of this posting, was 10,092,710.

On Blog Comments:

The comments feature (by Disqus) for some reason unknown to me does not seem now to work for readers of this blog anymore. 

I don’t have the technical skills to make the nested comments feature work, so I will soon go back to the Google blogspot comments feature which will work without nesting offered by Disqus. Nesting, by the way, permits responses to particular comments rather than simply first in first out,. 

When I do make that change, I think that all of the prior comments will go away and be lost forever. But, on an ongoing basis, this should permit comments for those wishing to share comments with readers.


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Fourth Circuit Rejects Defendant's Collateral Attacks on Tax Perjury and Obstruction Convictions

In United States v. Sutherland, ___ F.4th ___, 2024 U.S. App. LEXIS 13117 (4th Cir. 2024), CA4 here and GS here, the Court rejects the criminal defendant’s collateral attacks on convictions for filing false tax returns and obstructing an official proceeding. (The latter conviction was for delivering false documents to the government attorney assisting the grand jury in the tax crimes investigation.) The collateral attacks were mounted by a petition under 28 USC § 2255 and a petition for the writ of coram nobis. The principal claim for both methods of collateral attack was an alleged ineffective assistance of counsel (“IAC”) at the criminal trial where the defendant was convicted. The defendant appealed the convictions, and the Fourth Circuit affirmed. United States v. Sutherland, 921 F.3d 421 (4th Cir. 2019), GS here; see also Obstruction Conviction Affirmed for Presentation of False Documents to AUSA Serving as Attorney for Government for Grand Jury (4/26/19), here.