Jay Nanavati

Jay Nanavati

BakerHostetler

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The IRS Turns Up the Heat on Hedge Fund-Backed Reinsurance

After years of inaction, the Internal Revenue Service (IRS) is throwing up obstacles to enjoying the tax advantages of hedge fund-backed reinsurance. On April 24, 2015, the IRS issued a notice of proposed rulemaking titled...more

6/10/2015 - Foreign Insurance Companies Hedge Funds IRS NPRM Passive Foreign Investment Company Reinsurance

Global Tax Enforcement in 2015: What You Need to Know

Tax fraud occurs on a considerable scale that can exceed law enforcement’s ability to detect and punish the conduct. This is true at both the federal and state levels. As of 2015, the Internal Revenue Service (“IRS”) and the...more

6/2/2015 - Banking Sector DOJ FATCA IRS OECD Offshore Funds OVDP Strategic Enforcement Plan Tax Evasion Tax Fraud

BSI Is First Bank to Reach Resolution in DOJ’s Program for Swiss Banks

BSI of Lugano, Switzerland, became the first bank to earn a non-prosecution agreement under the U.S. DOJ’s Program for Swiss Banks, paying a penalty of $211 million. First announced on August 29, 2013, the program offered...more

4/1/2015 - Banks Corporate Fines DOJ Non-Prosecution Agreements Swiss Banks Tax Evasion

Ex-Credit Suisse Bankers Sentenced to Probation in Exchange for Cooperation

On March 27, 2015, a judge in the Eastern District of Virginia sentenced former Credit Suisse bankers Josef Doerig and Andreas Bachmann to five years of probation. Their sentences were the result of their cooperation with the...more

3/31/2015 - Banks C-Suite Executives Credit Suisse Criminal Prosecution Enforcement Actions

Update: Banca Privada d’Andorra Succumbs After FinCEN Action

On March 16, 2015, the Spanish subsidiary of Banca Privada d’Andorra, Banco de Madrid, sought bankruptcy protection in the midst of a run on the bank by depositors. ...more

3/19/2015 - Banca Privada d' Andorra Commercial Bankruptcy Enforcement Actions FinCEN

FinCEN Blacklists Banca Privada d’Andorra

On March 10, 2015, FinCEN designated Banca Privada d’Andorra, based in the Principality of Andorra, as a foreign financial institution of primary money-laundering concern pursuant to Section 311 of the USA PATRIOT Act...more

3/12/2015 - Banca Privada d' Andorra Blacklist FFI FinCEN Money Laundering Patriot Act

New York Restaurateur Pleads Guilty to Hiding Money in Swiss Accounts

On February 19, 2015, Georges Briguet, the owner of New York restaurant Le Perigord, pleaded guilty to one count of corruptly endeavoring to obstruct the IRS by concealing the existence of his Swiss bank accounts. According...more

2/23/2015 - IRS Offshore Funds Tax Evasion

Former Wegelin Banker Reportedly Arrested on U.S. Warrant in Germany

Multiple outlets are reporting that on February 2, 2015, three years after his indictment in the Southern District of New York, Swiss banker Roger Keller was arrested at the Frankfurt airport. On January 3, 2012, the U.S....more

2/10/2015 - Criminal Prosecution Extradition Indictments Roger Keller Tax Evasion

California Physician Pleads Guilty to Failing to File FBAR for Bank Leumi Account

On February 2, 2015, Baruch Fogel, a California doctor, pleaded guilty in the U.S. District Court for the Central District of California to one count of willful failure to report the existence of a foreign bank account on a...more

2/4/2015 - Civil Monetary Penalty Criminal Prosecution FBAR Foreign Bank Accounts

Bank Leumi Enters Into DPA with U.S. Department of Justice

A major Israeli international bank admitted that it conspired to aid and assist U.S. taxpayers to prepare and present false tax returns to the Internal Revenue Service (IRS) by hiding income and assets in offshore bank...more

12/23/2014 - Deferred Prosecution Agreements DOJ Enforcement Actions Foreign Bank Accounts IRS Offshore Funds

Singapore Signs FATCA IGA

On December 9, 2014, Singapore’s Inland Revenue Authority announced that Singapore and the United States had on that day entered into a Model 1 FATCA IGA. ...more

12/11/2014 - FATCA Intergovernmental Agreements Singapore

Treasury Announces Relief for Countries with In-Substance FATCA IGAs

On December 1, 2014, the U.S. Treasury Department announced that countries that have reached FATCA inter-governmental agreements (IGAs) in substance but have not signed the agreements by the December 31 deadline will, under...more

12/3/2014 - FATCA Intergovernmental Agreements U.S. Treasury

Hong Kong Signs FATCA IGA

On November 13, 2014, Hong Kong announced that it had signed a Model 2 FATCA IGA. Under the agreement Hong Kong financial institutions will enter into separate FFI agreements with the IRS and will report information on U.S....more

11/18/2014 - FATCA FFI Hong Kong Intergovernmental Agreements IRS

FinCEN Strikes at Virtual Currency Anonymity, Rules that Virtual Currency Converter is a Money Services Business Under Bank...

On October 27, 2014, FinCEN ruled in response to a Request for Administrative Ruling that a company that converts traditional currencies into Bitcoin to facilitate payments must comply with regulations that govern Money...more

11/3/2014 - Bank Secrecy Act Bitcoins FinCEN Money Services Business

New Hampshire Man Pleads Guilty Regarding Accounts in Switzerland, Israel, and Jersey

On October 20, 2014, Menashe Cohen pleaded guilty in New Hampshire federal court to one count of filing a false income tax return for failing to report the existence of his Swiss and Israeli bank accounts on his 2009 tax...more

10/22/2014 - Criminal Prosecution Foreign Banks Income Taxes Tax Evasion Tax Fraud

Switzerland Announces Intention to Change from Model 2 IGA to Model 1

On October 8, 2014, Swiss officials announced that they intend to negotiate a reciprocal Model 1 FATCA IGA to replace the Model 2 IGA that they signed in 2013. The motivation for the change is unknown, but the automatic...more

10/10/2014 - FATCA Intergovernmental Agreements Switzerland Transparency

Forensic Accountant and Certified Fraud Examiner Pleads Guilty to Concealing UBS Account

On October 3, 2014, according to a U.S. Attorney’s Office press release and court records, Howard Bloomberg, a forensic accountant and certified fraud examiner, pleaded guilty to one count of failure to file an FBAR reporting...more

10/8/2014 - FBAR Fraud Tax Evasion UBS

Bank Julius Baer Customer Implicated in Alleged Tax Fraud

Reuters is reporting that Bank Julius Baer is cooperating with French authorities in their criminal investigation into an alleged value-added-tax (“VAT”) fraud in the EU Emissions Trading System. ...more

10/3/2014 - Corporate Taxes Emissions Trading System EU Foreign Banks Investigations Tax Fraud Value-Added Tax

American Pleads Guilty to Hiding Money in Swiss Bank, Moving Money to Israeli Bank after UBS Scandal

On August 19, 2014, Bernard Kramer pleaded guilty in the Southern District of New York to conspiracy to defraud the United States and filing a false income tax return relating to his concealment of “at least $1.1 million” in...more

8/26/2014 - Foreign Banks Fraud Income Taxes Offshore Funds Tax Evasion

Treasury’s FinCEN Proposes Rules Forcing U.S. Financial Institutions to Collect Data for FATCA Reciprocity

On July 30, 2014, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) proposed rules requiring U.S. financial institutions to collect “Customer Due Diligence” information, including identifying the true...more

8/1/2014 - FATCA FinCEN Income Taxes International Tax Issues Tax Evasion

China and U.S. Conclude FATCA IGA In Substance

On June 26, 2014, China and the United States agreed on a Model 1 FATCA IGA. The Treasury did not say whether the agreement would be reciprocal. The IGA comes just in time for the July 1 start of 30 percent withholding on...more

6/30/2014 - China FATCA FDAP FFI Intergovernmental Agreements

Former Head of DOJ Tax Division Warns Taxpayers to Think Twice Before Choosing New Streamlined Procedures

Former DOJ Tax Division AAG Kathy Keneally warned on June 24, 2014, that taxpayers should think carefully before signing a certification of non-willfulness and entering the IRS’s new Streamlined Filing Compliance Procedures....more

6/26/2014 - DOJ FATCA FBAR IRS Tax Evasion Tax Liability Tax Penalties

IRS Announces Major Changes to OVDP

On June 18, 2014, the IRS announced major changes to the OVDP, including a major expansion of the so-called Streamlined Program and an increased penalties for taxpayers who held accounts at banks that are under criminal...more

6/20/2014 - FBAR Income Taxes IRS OVDP

Hong Kong Agrees in Substance to FATCA IGA

On May 9, 2014, the U.S. Treasury announced that Hong Kong had agreed in substance on a Model 2 FATCA IGA. Under the IGA, Hong Kong financial institutions will report information on financial accounts held by U.S. persons...more

5/12/2014 - FATCA Hong Kong IRS U.S. Treasury

Swiss Financial Institution Pays $4.4 Million and Turns Over 110 Americans

Bloomberg BNA reported on May 9, 2014, that Swisspartners Group resolved a U.S. criminal tax probe by forfeiting $3.5 million and paying $900,000 in restitution for helping U.S. clients evade taxes with secret accounts. ...more

5/12/2014 - Offshore Banks Offshore Funds Swisspartners Group Tax Evasion

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