Jay Nanavati

Jay Nanavati

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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

Cayman Islands and U.S. Sign FATCA IGA

On November 29, 2013, the Cayman Islands and the U.S. Signed a FATCA IGA. The Cayman Islands IGA is a Model 1B agreement, meaning that FFIs in the Cayman Islands will be required to report tax information about U.S. account...more

12/2/2013 - FATCA IGA International Tax Issues IRS OVDP Tax Evasion TIEA

Voluntary Disclosures Lead to John Doe Summonses for Information about U.S. Accounts at Zurcher Kantonalbank and Bank of...

In a sign that the U.S. government continues to aggressively seek information on U.S. taxpayers with non-U.S. bank accounts, the government announced on November 12, 2013, that it had obtained a court order authorizing the...more

11/15/2013 - Bank Accounts Banks Foreign Bank Accounts John Doe Investigation Summons Voluntary Disclosure

IRS Official Announces Crackdown on U.S. Taxpayers with Unreported Indian Accounts

Tax Analysts Tax Notes reports that the IRS Small Business/Self-Employed Division's special enforcement program (SEP) will soon begin examining U.S. taxpayers suspected of holding undeclared accounts in Indian banks. An IRS...more

11/15/2013 - India IRS Offshore Funds Tax Evasion

U.S. Signs FATCA IGA With France

Bloomberg BNA reports that the Treasury Department announced on November 14, 2013, that the U.S. and France have signed a Model 1 FATCA IGA. In other words, the IGA will require banks in France to report tax information about...more

11/15/2013 - EU FATCA IGAs U.S. Treasury

Federal Court Shuts Down Instant Tax Service

Tax Analysts Tax Notes reports that on November 6, 2013, Judge Timothy S. Black of the Southern District of Ohio permanently shut down Instant Tax Service, which claims to be the fourth largest tax return preparation firm in...more

11/12/2013 - Fraud Tax Preparers

U.S. Seeks John Doe Summonses for Two More U.S. Banks

The Chicago Tribune reports that U.S. authorities are seeking information from Citigroup Inc.’s Citibank NA and Bank of New York Mellon Corp to uncover the identities of U.S. citizens who may have been hiding money in Swiss...more

11/8/2013 - Banks IRS John Doe Investigation Summons

IRS Announces New Mandatory IDR Procedures

Tax Analysts Tax Notes reports that the IRS Large Business and International Division (LBI) released mandatory, stringent new procedures for enforcing information document requests (IDRs) and issuing summonses, minimizing...more

11/7/2013 - Document Requests IRS Request For Information

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