Tax and Accounting Correspondent
Lynnley's Feed
May 15, 2012

HP loses $190 million tax case against IRS

May 14 (Reuters) – Hewlett-Packard Co. on Monday lost a
battle with the U.S. Internal Revenue Service for more than $190
million in tax refunds tied to a Dutch tax shelter designed by
the derivatives arm of American International Group.

The ruling turns a spotlight on an aggressive tax-cutting
strategy created last decade by AIG Financial Products and
bankrolled by several European banks.

Apr 23, 2012
via Tax Break

Fate of ex-UBS client cases uncertain, lawyers say


Tax lawyers are divided over the legal consequences of the bruising defeat in court of a billionaire former client of UBS AG who sued the Swiss bank for allegedly giving him incorrect tax advice.

On April 10, Judge Andrew Guilford of U.S. District Court in Santa Ana, Calif., dismissed a case brought by Igor Olenicoff, a Russia-born property developer. Olenicoff had accused the bank of improperly telling him he didn’t have to disclose certain Swiss-held assets on his U.S. tax returns.

Apr 10, 2012

UBS fends off lawsuit of billionaire US tax evader

April 10 (Reuters) – A U.S. federal judge ruled on Tuesday
in favor of Swiss bank UBS AG in a lawsuit brought by Igor
Olenicoff, a billionaire former client who ran afoul of the
tax-collecting Internal Revenue Service and tried to blame the

Olenicoff sued UBS in 2008, accusing the bank of fraud,
conspiracy and other charges in handling some $200 million he
kept in offshore accounts and claiming that UBS had wrongfully
advised him that he did not have to report them to the IRS.

Apr 5, 2012

Odds favor IRS in Supreme Court tax cases: study

By Lynnley Browning

(Reuters) – The odds are stacked against corporations whose disputes with the tax-collecting Internal Revenue Service go all the way to the Supreme Court, a new study found.

Titled “Corporate Shams,” the study by two tax scholars at U.S. universities, found the government prevailed more than six times out of 10 in high court cases where it argued that corporations actively abused the tax code.

Mar 30, 2012

Lawsuits test UBS advice on offshore bank accounts

March 30 (Reuters) – The case of a wealthy U.S. businessman
who pleaded guilty to evading taxes but then sued the Swiss bank
where he hid his money is scheduled to go to trial on May 8, the
first major test of civil legal challenges to Swiss banks that
sold offshore private banking services to help Americans evade

The civil suit, filed against UBS AG in federal
court in Santa Ana, California – and another filed against UBS
in federal court in Chicago – will probe whether clients can
legally rely on their private bankers’ assertions there is no
need to disclose the accounts on their tax returns or sign
required disclosures.

Mar 14, 2012

Two Swiss financial advisers indicted in U.S.

By Lynnley Browning

(Reuters) – Posecutors in New York on Wednesday indicted two Swiss financial advisers, one a former private banker at financial giant UBS AG, on charges of conspiring to help wealthy Americans hide $267 million in secret bank accounts.

In separate indictments, one of them alleging that a child was used to carry cash to a client, charges were brought against Hans Thomann, 61, and Josef Beck, 46. Both live in Switzerland, but they worked separately from each other.

Feb 23, 2012
via Tax Break

Romney’s 2010 IRS return flags complex tax strategies


U.S. Republican presidential candidate Mitt Romney. REUTERS/Laura Segall

Republican presidential candidate Mitt Romney’s release of his 2010 tax return offers a rare glimpse at two sophisticated tax transactions which the U.S. Internal Revenue Service requires that taxpayers disclose for investments driven by tax considerations.

Like thousands of other Americans’ returns, Romney’s included special attachments flagging “reportable transactions” to the IRS. Known as Form 8886s, the attachments showed that these foreign currency and contingent swap transactions were undertaken by one Bain Capital fund and three Goldman Sachs funds in which blind trusts for the assets of Romney and his wife Ann have invested several million dollars.

Feb 16, 2012

Oldest Swiss private bank is newest U.S. target

GALLEN, Switzerland, Feb 16 (Reuters) – On the
morning of Jan. 27, employees at the St. Gallen headquarters of
Wegelin, Switzerland’s oldest private bank, were told to expect
an important announcement from Konrad Hummler, Wegelin’s leading
partner. Other Wegelin branches across Switzerland, also
alerted, tuned in to the company-wide address system.

Speaking in Swiss-German, Hummler announced the bank had
sold most of its assets to another Swiss bank. According to a
person familiar with the matter, Hummler called it a last-ditch
effort to preserve employees’ jobs amid withdrawals of assets by
investors who were increasingly worried about a growing problem:
a U.S. federal investigation into Wegelin’s sale of tax-evasion
services to wealthy Americans. The dark-suited bankers and
conservatively dressed office clerks, said the person, were in
shock and tears.

Feb 13, 2012

Detained Swiss banker’s fate up in the air

FORT LAUDERDALE, Florida (Reuters) – A Swiss private banker, held on a criminal complaint for 13 months without a formal indictment, was on Monday given 60 more days by a Florida court to go on trying to resolve the issue with U.S. authorities.

Christos Bagios, a Greek citizen and Swiss resident, was due

either to be indicted or have his case dismissed, but instead was granted the extension by Judge Lurana Snow in a federal courtroom in Ft. Lauderdale.

Feb 8, 2012

U.S. enlists 5 EU nations in offshore tax crackdown

By Lynnley Browning

(Reuters) – The U.S. Treasury Department on Wednesday enlisted five EU nations to help crack down on offshore tax evasion by Americans and ease the burdens the effort has imposed on many banks and financial institutions.

After complaints from the global financial industry about costs and legal issues, Treasury announced a new multilateral approach to implementing the Foreign Account Tax Compliance Act, or FATCA.