Whistleblower Suit Against Citigroup

Practical and Practice issues for Professionals who practice in the area of taxation. Moral, social and economic issues relating to taxes, including international issues, the U.S. Internal Revenue Code, state tax issues, etc. Not for "tax protestor" issues, which should be posted in the "tax protestor" forum above. The advice or opinion given herein should not be relied on for any purpose whatsoever. Also examines cookie-cutter deals that have no economic substance but exist only to generate losses, as marketed by everybody from solo practitioner tax lawyers to the major accounting firms.
User avatar
Number Six
Hereditary Margrave of Mooloosia
Posts: 1111
Joined: Fri Aug 29, 2008 7:35 pm
Location: Connecticut, "The Constitution State"

Whistleblower Suit Against Citigroup

Postby Number Six » Wed Oct 21, 2015 2:45 pm

http://www.nytimes.com/2015/10/20/busin ... =RecEngine

What stood out for me here was what standing did the professor have to file the suit? If this suit is successful it should set a useful precedent to allow other whistleblowers to file similar suits.
'There are two kinds of injustice: the first is found in those who do an injury, the second in those who fail to protect another from injury when they can.' (Roman. Cicero, De Off. I. vii)

'Choose loss rather than shameful gains.' (Chilon Fr. 10. Diels)

Hyrion
Admiral of the Quatloosian Seas
Admiral of the Quatloosian Seas
Posts: 616
Joined: Thu Nov 13, 2014 2:33 pm

Re: Whistleblower Suit Against Citigroup

Postby Hyrion » Wed Oct 21, 2015 6:27 pm

I'm more curious how an economics professor got hold of the detailed tax documents that a Corporation filed with the IRS.

Citigroup trades on the NYSE so it's a public company in that context.

Documents I've seen presented in annual statements and such don't include the specific details that would be in a tax filing - which I would deduce one would need in order to complete one's own analysis of what taxes should have been paid.

Perhaps there's a particular form that needs to be filed with the SEC that would contain such details?

Or can that kind of information be acquired through a freedom of information request?

Edited to add:

Ahh - I see. After finishing a review of the article, it's not so much a "whistleblower vs citigroup" as it is a "whistleblower vs the federal government decision on a tax exemption". Which means it was likely public knowledge and the actual detailed tax documents wouldn't have been part of the picture. Scratch my original curiosity.

User avatar
Dr. Caligari
J.D., Miskatonic University School of Crickets
Posts: 1515
Joined: Fri Jul 25, 2003 11:02 pm
Location: Southern California

Re: Whistleblower Suit Against Citigroup

Postby Dr. Caligari » Wed Oct 21, 2015 6:49 pm

What stood out for me here was what standing did the professor have to file the suit? If this suit is successful it should set a useful precedent to allow other whistleblowers to file similar suits.


New York State has a statute-- unique to New York, as far as I can tell-- which allows a whistleblower to file a suit against a defendant who underpaid New York State taxes. (The recovery goes to the State, but the plaintiff-whistleblower gets a cut.) Since New York tax law borrows from the federal IRC, an underpayment of federal taxes by a New York resident will almost always result in an underpayment of New York taxes. So the lawsuit here-- although aimed at a federal IRS ruling-- technically challenges only Citibank's New York State tax filings.
Dr. Caligari
(Du musst Caligari werden!)


Return to “Tax Practice & Policy and Tax Shelters”

Who is online

Users browsing this forum: No registered users and 1 guest