Category: Tax Cases

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Recently enacted legislation termed “CTA” may affect your tax planning.

The recently enacted legislation is part of the National Defense Authorization Act (NDAA) enacted by Congress on January 1, 2021, through the override of a presidential veto. The NDAA is a series of federal laws primarily specifying the annual budget and expenditures of the United States Department of Defense. The NDAA for Fiscal Year 2021 includes the expansive Anti-Money Laundering Act of 2020 (AMLA). The AMLA bolsters existing anti-money laundering legislation through several amendments to the Bank Secrecy Act (BSA), which has been the primary statutory vehicle for financial institutions to assist the federal government in detecting and preventing money laundering since its passage in 1970. The amendme

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U.S. INDIVIDUALS ALLEGED TAX CRIMINALS BY DENMARK

Part III.

SETTLEMENT REACHED WITH NORTH CHANNEL BANK In August of 2020, the North Channel Bank offered an unusual statement in their website addressing the indictment proceedings of the Kingdom of Denmark against North Channel Bank. Below are excerpts of this statement:

“Over the past three years, under the current management, the bank has cooperated with the investigating authorities in a very transparent manner and supported the investigations.” The business organization under the Bank’s name was used to facilitate”…the illegal cum-ex business at the expense of Denmark and Belgium was already ceased by the current management in early 2017.” The Bank did act quickly to remove any employees where

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U.S. INDIVIDUALS ALLEGED TAX CRIMINALS BY DENMARK Part II. INDIVIDUALS AND COMPANIES IDENTIFIED. As discussed in Part I. of this continuing Article, Denmark is vigorously looking for the 6 individuals who have allegedly defrauded the Government of Denmark of more than $2.1 billion via a dividend-tax
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On April 13, 2021, the Danish State Prosecutor for Serious Economic and International Crime publicly named and charged 3 U.S. residents and 3 British residents with defrauding the Danish tax authorities of more than US$176 million in a sham trading scheme called “cum-ex” which is Latin meaning “with-without” that illustrates the vanishing of dividend payments. In summary, this dividend scheme is believed to involve the trading of company shares rapidly around a syndicate of banks, investors, and hedge funds to suggest numerous owners, each entitled to a tax rebate from the Danish Government which is fraudulent and patently illegal.

Earlier, in January of 2021, 2 UK citizens were charged in this illegal scheme that brings in a current total of 8 non-Danish individuals. Of

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Robert F. Smith Background and Non-Prosecution Agreement INTRODUCTION: Mr. Smith in 2020, at the age of 57, entered into a Non-Prosecution Agreement, NPA, with the IRS.   Let’s look at what I believe happened to Mr. Smith to cause his personal and professional life to intersect with potential
10.82 Expedited suspension (a) When applicable. Whenever the Commissioner, or delegate, determines that a practitioner is described in paragraph (b) of this section, the expedited procedures described in this section may be used to suspend the practitioner from practice before the Internal Revenue Service.

(b) To whom applicable. This section applies to any practitioner who, within 5 years prior to the date that a show-cause order under this section’s expedited suspension procedures is served:

(1) Has had a license to practice as an attorney, certified public accountant, or actuary suspended or revoked for cause (not including failure to pay a professional licensing fee) by any authority or court, agency, body, or board described in § 10.51(a)(10).

(2) Ha