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US targets the use of LLCs to disguise foreign beneficial owners

The United States Department of Treasury issued proposed regulations that, if promulgated, would impose new disclosure obligations on domestic disregarded entities wholly owned by foreign persons (i.e., single-member limited...more

First bank resolution announced by DOJ: US taxpayers advised that time is running out to come forward

On March 30, 2015, the US Department of Justice announced the first non-prosecution agreement entered into by a Swiss bank pursuant to the Swiss Bank Program and advised US taxpayers with secret offshore bank accounts that...more

US DOJ and Swiss government announce new voluntary disclosure program for Swiss banks

In recent years, the US Department of Justice has been aggressively investigating the use of bank accounts outside the US to evade tax. While emphasizing that its enforcement activities are and must remain global, the DOJ has...more

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