Jay Nanavati

Jay Nanavati

BakerHostetler


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The 2012 FBAR Filing Deadline is June 30, 2013

U.S. taxpayers with foreign accounts whose aggregate value exceeded $10,000 at any time during 2012 must file Treasury Department Form TD F 90-22.1 (Report of Foreign Bank and Financial Accounts) with the Treasury Department...more

6/19/2013 - Disclosure Requirements FBAR Foreign Bank Accounts Penalties U.S. Treasury

IRS Rules that Mexican Fideicomisos or Land Trusts are not Trusts for U.S. Tax Purposes

On June 6, 2013, the IRS released Revenue Ruling 2013-14, which holds that Mexican fideicomisos or Land Trusts are not trusts for U.S. tax purposes. “Fideicomisos have been an issue in the offshore disclosure world for quite...more

6/7/2013 - Disclosure Requirements Fideicomisos IRS Offshore Funds

Indian American Neurosurgeon Sentenced to Probation for Unreported Offshore Bank Accounts

On February 1, 2013, the U.S. District Court for the Eastern District of Wisconsin sentenced Arvind Ahuja, a Milwaukee neurosurgeon, to serve three years of probation and to pay a fine of $350,000 following his conviction by...more

5/21/2013 - Criminal Prosecution DOJ FBAR Income Taxes Offshore Funds Tax Evasion

Government Runs Its Record to 4-0 in Compelling Production of Records of Offshore Bank Accounts

On February 7, 2013, the U.S. Court of Appeals for the Eleventh Circuit joined “the three of our sister circuits that have considered the same issue here about foreign financial account records and conclude that the...more

5/21/2013

Supreme Court Settles Fifth Amendment Required Records Issue in Context of Offshore Bank Accounts

On May 13, 2013, the Supreme Court denied a taxpayer’s petition for certiorari regarding the Seventh Circuit’s August 27, 2012, decision applying the Required Records Exception to override the taxpayer’s Fifth Amendment...more

5/21/2013 - Fifth Amendment Offshore Funds Recordkeeping Requirements Required Documentation SCOTUS

New Jersey Businessman With NRI Account Pleads Guilty to Using Offshore Bank Accounts to Defraud the U.S. and Pays $2.37 Million...

Sanjay Sethi, a New Jersey businessman, pleaded guilty on January 7, 2013 to using hidden offshore bank accounts to defraud the U.S. in a so-called “Klein conspiracy.”...more

1/15/2013 - FATCA FBAR Income Taxes IRS Offshore Voluntary Disclosure Program Penalties Tax Penalties

Ninth Circuit Holds that Fifth Amendment Does Not Shield Taxpayer's Attorney from Forced Production of Client-Taxpayer's Records

Applying the “foregone conclusion” exception to the Fifth Amendment privilege against self-incrimination, the Ninth Circuit held on January 8, 2013, that the IRS could force a taxpayer’s criminal defense attorney to turn over...more

1/15/2013 - Client-Taxpayer Records Document Productions DOJ Fifth Amendment Foregone Conclusion Exception IRS Self-Incrimination Summons

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