The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Sept. 10, 2024, issued four FAQs to update and clarify how reporting should be undertaken for reporting companies that are dissolved prior...more
The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) on Feb. 7, 2024, issued a Notice of Proposed Rulemaking (NPRM) proposing a new nationwide reporting obligation to be imposed on settlement...more
2/27/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Cash Transactions ,
Corporate Transparency Act ,
FinCEN ,
Geographic Targeting Order ,
GTO ,
NPRM ,
Proposed Regulation ,
Real Estate Transfers ,
Reporting Requirements ,
Residential Real Estate Market ,
Suspicious Activity Reports (SARs) ,
Terrorist Financing Regulations ,
Title Insurance ,
Trusts ,
U.S. Treasury
The attorney-client privilege is one of the bedrocks of the legal profession. It permits communications between a client and an attorney to remain privileged. The U.S. Supreme Court has stated that by assuring...more
The latest U.S. Department of the Treasury Report reflects that a record 6,047 individuals expatriated during the first three quarters of 2020. This compares to the previous annual record…...more
The IRS currently offers the following five programs for noncompliant taxpayers: (i) the Offshore Voluntary Disclosure Program (OVDP), (ii) Streamlined Domestic Offshore Procedures, (iii) Streamlined Foreign Offshore...more
12/24/2016
/ Bad Boy Liability ,
Criminal Conspiracy ,
Criminal Investigations ,
Delinquent Filer Voluntary Compliance ,
Expatriates ,
False-Certification of Conformance ,
FATCA ,
FBAR ,
Foreign Financial Accounts ,
Foreign Financial Institutions (FFI) ,
Guilty Pleas ,
International Consortium of Investigative Journalists (ICIJ) ,
IRS ,
OVDP ,
Panama Papers ,
Swiss Banks ,
Tax Evasion ,
Tax Fraud ,
Tax Penalties ,
Whistleblowers
According to the Miriam Webster dictionary, credibility is defined as "the quality or power of inspiring belief." When IRS Commissioner John Koskinen took office, one of his many roles involved trying to restore the integrity...more
States are fighting back. While they may not have the same resources available to combat tax avoidance, as the Internal Revenue Service or Department of Justice, they are resorting to creative measures.
...more
3/28/2014
On March 20, 2014, a federal grand jury in Kansas City, Missouri indicted Victor Lipukhin for tax crimes that occurred from 2002-2007. What makes this indictment stand out when compared against many others is that the...more
In a move that was likely celebrated by United States governmental officials, Swiss banking secrecy eroded even further on Thursday, March 6, 2014. This is the day that parliament voted to provide foreign tax authorities with...more
Two interesting stories coming out of California were reported in the media last week, both of which dealt with the issue of what constitutes taxable income. Generally speaking Internal Revenue Code Section 61 defines what...more
While Israel welcomes immigrants, and even provides them with tax incentives, it is serious about ending any perceived notion that it is somehow complicit with taxes evaded by its foreign residents in their home country. As...more
Today, February 26, 2014, the Senate Permanent Subcommittee on Investigations will hold a hearing on offshore tax evasion titled “Offshore Tax Evasion: The Effort to Collect Unpaid Taxes on Billions in Hidden Offshore...more
On Tuesday, February 18, 2014, the Treasury Inspector General for Tax Administration (TIGTA) issued a report reviewing the long-term travel of certain IRS executives and found that nine of the thirty one executives whose...more
Anyone can become a victim of identity theft, and it can happen anywhere. Michael Stores, Neiman Marcus and Target are simply the latest merchants to report that customer information was stolen. While being a victim of...more
There are a multitude of information returns that United States taxpayers may need to file if they own foreign assets or have foreign investments. Two of these forms are the FBAR (Foreign Bank Account Report) and Form 8938...more
The Report of Foreign Bank and Financial Accounts (FBAR) can no longer be filed on TDF 90-22.1, and must be e-filed on Form 114. This alert summarizes developments involving FBAR e-filing and signature authority. They are...more
1/29/2014
/ Anti-Money Laundering ,
Bank Secrecy Act ,
Banking Sector ,
FBAR ,
FinCEN ,
Foreign Banks ,
Foreign Investment ,
IRS ,
Offshore Banks ,
Offshore Funds ,
Reporting Requirements
Much has been written about the IRS's dogged pursuit of taxpayers with unreported foreign accounts. These accounts are reported on the Report of Foreign Bank and Financial Accounts (FBAR) when a taxpayer has a financial...more
Earlier this month, the First Circuit Court of Appeals held in a case of first impression that evidence seized by IRS special agents from the taxpayer's home was admissible even though IRS Special Agents were armed when they...more
Many foreigners crave United States citizenship even though it comes with corresponding obligations and responsibilities (i.e., think about tax compliance). CBS News previously wrote about pregnant women from foreign...more
As of January 1, 2013, United States banks were required to report to the IRS interest earned by nonresident aliens who are residents of certain foreign countries. The reporting requirement previously existed for accounts...more