Jay Nanavati

Jay Nanavati

BakerHostetler

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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

Singapore Agrees in Substance to FATCA IGA

On May 6, 2014, the Ministry of Finance of Singapore announced that Singapore had agreed in substance on a Model 1 FATCA IGA. Under the IGA, Singapore-based financial institutions will report information on financial accounts...more

5/8/2014 - FATCA FATCA Timeline IRS Monetary Authority of Singapore

Israel Inks Model 1 FATCA IGA

Bloomberg BNA is reporting that Israel has signed a FATCA IGA. The agreement is a Model 1 agreement, meaning that Israeli financial institutions will will report information about U.S. customers’ accounts to the Israeli tax...more

5/2/2014 - FATCA IGAs IRS

Ex-Israeli Banker Indicted for Assisting Americans in Tax Fraud

On April 30, 2014, a federal grand jury in Los Angeles, California, indicted Shokrollah Baravarian for Klein conspiracy: conspiracy to defraud the United States by impairing and impeding the IRS. ...more

5/2/2014 - Conspiracies IRS Tax Evasion Tax Fraud

Fugitive Swiss Banker Returns to U.S. and Enters Guilty Plea

On April 30, 2014, Josef Dorig, 72, of Switzerland, pleaded guilty in federal district court in Alexandria, Virginia, to a single count of Klein conspiracy: conspiracy to defraud the U.S. by impairing and impeding the IRS....more

5/1/2014 - Credit Suisse Criminal Conspiracy DOJ EU International Bank IRS Offshore Banks Offshore Funds Tax Haven

India Agrees “In Substance” to Model 1 FATCA IGA

The U.S. Treasury announced that on April 11, 2014, India agreed “in substance” to sign a Model 1 FATCA IGA with the US. The IGA would therefore require Indian financial institutions to report information on U.S. account...more

4/29/2014 - FATCA India IRS Reporting Requirements U.S. Treasury

U.S. Signs FATCA IGA with Luxembourg

On March 28, 2014, the U.S. signed a FATCA IGA with Luxembourg. Under the IGA, banks and other financial institutions in Luxembourg will report information about eligible U.S. customers’ offshore accounts to the Luxembourg...more

4/1/2014 - EU FATCA

Levin and McCain Urge DOJ to Seek Extradition of Fugitive Swiss Bankers

Bloomberg news reports that on March 18, 2014, U.S. Senators Carl Levin and John McCain wrote a letter urging the Justice Department to seek extradition of about 30 Swiss bankers and others who are charged with enabling...more

3/28/2014 - DOJ Extradition Foreign Banks Tax Evasion

OECD Publishes Standard for International Automatic Tax Information Exchange

On February 13, 2014, the OECD published a standard for the automatic exchange of tax information among governments, intended to help fight cross-border tax evasion. Under the standard, governments would collect information...more

2/17/2014 - FATCA OECD Tax Evasion

Swiss Investment Adviser to Plead Guilty to Helping Americans Evade Taxes

Multiple outlets are reporting that on February 26, 2014, Martin Lack, a Swiss investment adviser and former UBS banker, will plead guilty in the Southern District of Florida to one count of conspiracy to defraud the United...more

2/14/2014 - Foreign Nationals Guilty Pleas Investment Adviser Tax Evasion

U.S. Signs Four More FATCA IGA’s

On February 5, 2014, the Treasury Department announced that it had recently concluded FATCA IGA’s with Canada, Hungary, Italy, and Mauritius. All four agreements were reciprocal Model 1 agreements. In other words, FFI’s in...more

2/7/2014 - Banks FATCA FFI Foreign Banks IGAs

U.S. Signs FATCA IGA with Italy

Tax Analysts’ Tax Notes Today reports that on January 10, 2014, the U.S. signed a FATCA IGA with Italy, which became the 13th country to sign such a deal with the U.S. ...more

1/27/2014 - EU FATCA IGAs

Beanie Babies Creator Seeks Probation for $107 Million UBS Account

The Chicago Tribune reports that Beanie Babies creator Ty Warner, who pleaded guilty last year to one of the largest tax frauds in Chicago-area history, has asked the federal court to sentence him to probation. His sentencing...more

1/7/2014 - Foreign Bank Accounts OVDP Tax Evasion Tax Fraud UBS

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