Brian McManus

Brian McManus

Latham & Watkins LLP

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Foreign Banks and Bankers Face New Risks From Swiss Bank Amnesty

The first non-prosecution agreement signals expanded US tax enforcement opportunities at home and abroad. The US Department of Justice (DOJ) has announced the first non-prosecution agreement (NPA) with BSI, SA, (BSI)...more

4/16/2015 - Banks BSI SA DOJ FATCA FFI Foreign Banks IRS Non-Prosecution Agreements OVDP Swiss Banks Tax Evasion

Bandfield Confirms Aggressive FATCA Enforcement Tactics

On Sept. 9, 2014, in U.S v. Robert Bandfield et al., federal prosecutors in the Eastern District of New York announced the indictment of a U.S. citizen and others, including offshore corporate service providers (CSPs) and...more

9/17/2014 - Enforcement Enforcement Actions FATCA International Tax Issues Offshore Funds Tax Evasion

FATCA Violation Underlies Latest US Tax and Securities Fraud Charges

Indictment demonstrates the strength of US law enforcement efforts to combat offshore fraud and is the first to charge a FATCA violation. On September 9, 2014, in US v. Robert Bandfield, et al., federal prosecutors in...more

9/16/2014 - Conspiracies Enforcement Actions FATCA FATCA Timeline Fraud Indictments Investment Adviser Money Laundering Offshore Companies Reporting Requirements Securities Fraud Tax Evasion Third-Party Service Provider

IRS Eases Access to Offshore Voluntary Disclosure Programs

The changes give taxpayers who mistakenly failed to report foreign assets a simpler path back to tax compliance. On June 18, 2014, the Internal Revenue Service (IRS) announced major modifications to the terms of its...more

6/25/2014 - FBAR Income Taxes IRS OVDP Tax Evasion

6 Reasons US Taxpayers Should Report Assets Held in Swiss Banks Soon

Initial success of DOJ Swiss bank amnesty program creates greater urgency for US taxpayers. On December 31, 2013, the window to apply for the US Department of Justice’s (DOJ) amnesty program closed for certain Swiss...more

2/4/2014 - DOJ FATCA Foreign Banks Non-Prosecution Agreements Offshore Banks OVDP Reporting Requirements Tax Amnesty Tax Evasion

US Allows Swiss Banks With Undisclosed Accounts To Wipe the Slate Clean

United States Department of Justice issues further information on amnesty program for Swiss banks, including details on the selection of an Independent Examiner. On November 5, 2013, United States Department of Justice...more

11/8/2013 - Banks DOJ Enforcement Foreign Bank Accounts Foreign Banks Tax Evasion

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