Jim Mastracchio

Jim Mastracchio

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

New IRS Offshore Disclosure Program Announced

On June 18, 2014, the IRS announced significant changes to its current Offshore Voluntary Disclosure Program (OVDP) and to the current version of the IRS Streamlined Filing Compliance Procedures (SFCP). Under the new...more

6/27/2014 - DOJ IRS OVDP Reporting Requirements

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

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

Taxpayer Advocate Continues to Criticize Offshore Voluntary Disclosure Programs

In an update to her December 2012 report, the Taxpayer Advocate has noted that the IRS still has not provided reasonable options for “benign actors”, or taxpayers who inadvertently violated the rules for reporting foreign...more

7/2/2013 - FBAR Foreign Bank Accounts IRS Offshore Funds OVDP

Tax Court Deals Another Blow to Conservation Easements

On June 24, 2013, the U.S. Tax Court disallowed a couple’s deduction for the donation of a conservation easement on the façade of a building to the National Architectural Trust, a qualified charitable organization. The court...more

6/28/2013 - Charitable Donations Conservation Easements IRS Tax Deductions

Department of Justice Sues Taxpayer to Collect $3.5 Million in FBAR Penalties, Possibly Putting Dutch Bank ABN AMRO's Swiss...

Carl R. Zwerner of Miami, Florida, is facing nearly $3.5 million in civil penalties for failing to report a Swiss bank account, according to a lawsuit filed by the Justice Department (United States v. Zwerner, S.D. Fla., No....more

6/20/2013 - DOJ FBAR Foreign Bank Accounts IRS Penalties Tax Returns

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

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