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The Cum-Ex Files

In Fraud by Jason B. FreemanLeave a Comment

Freeman Law recently reported on the Cum-Ex tax scandal in The Biggest Tax Heist Ever? The Cum-Ex Scandal–an alleged fraud that has been dubbed by some as “the most complicated” tax fraud case in history.  Since that time, the Eurpoean Union’s 55 billion euro cum-ex tax scandal has continued to expand.  (See Two More Bankers Arrested in Germany Over Cum-Ex …

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The Panama Papers: U.S. Accountant Pleads Guilty to Charges Related to Client’s Improper Filings

In Criminal, Fraud, Panama Papers by Jason B. FreemanLeave a Comment

A U.S. accountant pleaded guilty to charges of conspiracy to commit tax evasion and to defraud the United States in the second U.S. criminal conviction to arise out of the Panama Papers data leak.  The charges against the accountant-defendant included counts for wire and tax fraud, money laundering, failing to file FBARs, aggravated identity theft and other charges.  The guilty …

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FEDEX Bribe and Contract-Award Scandal

In Fraud, White Collar by Jason B. FreemanLeave a Comment

Five recently unsealed indictments (here, here, here, and here) allege a massive ten-year conspiracy to defraud that involved FedEx Ground Package System, Inc. (“FedEx”) management/employees and several contractors.  The conspiracy allegedly resulted in the wrongful payment of over $280,000,000 to the conspirators.[1] At the center of the conspiracy is FedEx Senior Line Manager Ryan Mower, who allegedly awarded contracts to conspirators …

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Restitution in Criminal Tax Cases

In Criminal, Fraud, Restitution by Jason B. FreemanLeave a Comment

Victims of federal crimes have a right to “full and timely restitution, as provided in law.”[1] Lacking the inherent authority to order restitution, courts can only order restitution when provided by statute. Once a court has ordered restitution, other governmental organizations play a role in enforcing the order and collecting the restitution, such as the Department of Justice, the Financial …

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J5 Continues its Efforts to Identity International Tax Cheats

In Fraud, International Tax, Offshore Tax by Matthew RobertsLeave a Comment

The Joint Chiefs of Global Tax Enforcement (known as the “J5”) has been busy the last few months.  The group – compromised of tax department heads from Australia, England, Canada, the Netherlands, and the United States – was formed in June 2018 to facilitate the sharing of information regarding international tax cheats.  A summary of some of their more recent …

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Where Is the Limit on Penalties for Willful FBAR Violations?

In Bank Fraud, Evasion, FBAR, Fines, Fraud, International Tax, Uncategorized by Ryan DeanLeave a Comment

A recent decision of the United States Court of Appeals, Federal Circuit holds that the pre-2004 regulation limiting willful FBAR penalties to a maximum of $100,000 is notapplicable.  As many tax practitioners know, 31 U.S.C. § 5314(a) requires taxpayers who have accounts with foreign financial institutions, specifically any person with a financial interest in or signature authority over foreign financial …