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First Circuit Liberalizes Tax Deductibility Standard of False Claims Act Settlements

Appellate court affirms $50 million tax refund to FCA defendant, holding that the “economic realities” of settlement payments determine whether they are compensatory. Civil False Claims Act (FCA) settlements, which...more

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

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

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