Wed, 22 May 2013
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Kings Bench barrister held in US over alleged $10m tax fraud
Whether Michael Little is or is not guilty of the offence he is charged with, he was a member of the New York Bar and accordingly it is to be assumed that he agreed at some point to uphold the law of the USA., Assuming that he was aware of those laws, as a member of the New York Bar, he should have known what risks (if any) he was taking in providing advice to his clients. However the bigger picture is that this is yet another example of the very aggressive stance being taken by the IRS towards overseas nationals providing tax mitigation advice to US citizens. It is the same aggressive stance that is causing the Swiss banking authorities to abandon 80 years of banking secrecy and which has already resulted in the demise of Switzerland's oldest private bank ( Bank Wegelin) and significant fines to be levied on several overseas banks, including a fine of circa $800m on UBS. There are no national barriers to the USA's ability to conduct military operations and there are no national barriers to the IRS enforcing US made tax law elsewhere in the world. This should be seen as a wake up call for anyone anywhere in the world who thinks it is safe or risk free to provide advice to a US citizen as to US tax liabilities.
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