Matthew Lee

Matthew Lee

Blank Rome LLP

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IRS Issues Last-Minute FBAR Filing Reminder

With the June 30 deadline to file the FBAR form fast approaching, the IRS issued another reminder to taxpayers with bank accounts located outside of the United States. The IRS noted that during 2014, the total number of FBAR...more

6/26/2015 - FBAR Filing Deadlines Filing Requirements FinCEN Foreign Bank Accounts IRS

BE-10 Report: The Overlooked International Reporting Form -The June 30 Deadline is Fast Approaching

The Bureau of Economic Analysis (“BEA”), an agency of the U.S. Department of Commerce, is currently conducting a benchmark BE-10 survey that requires the filing of a BE-10 report by any U.S. person that directly or indirectly...more

6/15/2015 - BEA Benchmarks Controlled Foreign Corporations Filing Requirements Foreign Affiliates Form BE-10

IRS Reminds Taxpayers with Foreign Assets of Their FBAR/FATCA Obligations As Key Deadline Approaches

Today the Internal Revenue Service issued two public notices reminding taxpayers of their obligations to report foreign assets as the June 30 FBAR deadline fast approaches. Each notice referred to the extensive guidance...more

6/11/2015 - FATCA FBAR Filing Deadlines Foreign Bank Accounts IRS

Two More Swiss Banks Reach Resolutions with U.S. Government

Today the Justice Department announced that Société Générale Private Banking (Suisse) SA (SGPB-Suisse) and Berner Kantonalbank AG (BEKB), have reached resolutions under the department’s Swiss Bank Program. With today’s...more

6/10/2015 - BEKB DOJ Foreign Financial Accounts Income Taxes IRS Non-Prosecution Agreements Offshore Banks OVDP SGPB-Suisse Swiss Banks

Two More Banks Reach Resolutions Under Justice Department’s Swiss Bank Program

On June 3, 2015, the Justice Department announced that two more Swiss banks, Rothschild Bank AG and Banca Credinvest SA, reached resolutions under the DOJ Swiss Bank Program. Yesterday’s announcement brings the total Swiss...more

6/6/2015 - Credinvest DOJ Foreign Bank Accounts Foreign Banks IRS Non-Prosecution Agreements Offshore Banks OVDP Rothschild Swiss Banks Tax Evasion

DOJ Announces Four More Swiss Bank Resolutions

Last week, the Justice Department announced that it had reached resolutions with four more Swiss banks under the terms of the DOJ Swiss Bank Program. The latest banks to resolve their U.S. tax issues are the following: ...more

6/1/2015 - Criminal Investigations Disclosure Requirements DOJ Foreign Banks International Tax Issues OVDP Swiss Banks

Justice Department Announces Second Swiss Bank Resolution

On May 8, 2015, the Justice Department announced publicly that it had reached resolution with Vadian Bank AG, of St. Gallen, Switzerland. This announcement marks only the second such resolution that the government has...more

5/12/2015 - DOJ Enforcement Actions Settlement Swiss Banks

FinCEN Announces First Civil Enforcement Action Against Virtual Currency Exchanger

Continuing its aggressive anti-money laundering enforcement agenda, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced yesterday that it had commenced the first-ever civil enforcement action...more

5/7/2015 - Civil Monetary Penalty Corporate Counsel Cryptocurrency Enforcement Actions FinCEN Money Transmitter Popular Registration Requirement Ripple Virtual Currency Young Lawyers

Latest GTO Reflects FinCEN’s Aggressive Approach to Anti-Money Laundering

On April 21, 2015, the Treasury Department’s Financial Crimes Enforcement Network issued a geographic targeting order, an anti-money laundering device focused on trade-based money laundering schemes used by drug cartels,...more

5/5/2015 - Anti-Money Laundering Bank Secrecy Act Cartels FinCEN Geographic Targeting Order ICE Illegal Drugs Trade-Based Money Laundering

Display of FinCEN’s Aggressive Anti-Laundering Approach

On April 21, 2015, the Treasury Department’s Financial Crimes Enforcement Network issued a geographic targeting order, an anti-money laundering device focused on trade-based money laundering schemes used by drug cartels,...more

5/1/2015 - Anti-Money Laundering Bank Secrecy Act Cartels Financial Institutions FinCEN Geographic Targeting Order Illegal Drugs Strategic Enforcement Plan Trade-Based Money Laundering

BSI Provides Road Map For Future Swiss Bank Agreements

On March 30, 2015, the U.S. Department of Justice announced that it had entered into a nonprosecution agreement with BSI SA, the first Swiss bank to reach resolution with the U.S. government as to its potential criminal...more

4/24/2015

On the Eve of Tax Day, DOJ Gently Reminds Taxpayers to File Timely and Accurate Returns

Every year as April 15 approaches, we observe an uptick in the frequency of Internal Revenue Service and Justice Department press releases announcing criminal charges against individuals accused of violating the tax laws. ...more

4/16/2015 - Criminal Prosecution DOJ IRS Press Releases Tax Returns

DOJ Announces Major Policy Change on Use of Asset Forfeiture for Structuring Offenses

We previously reported that the Internal Revenue Service had been criticized for its controversial, yet legal, practice of seizing bank accounts when the account holder is suspected of engaging in “structuring.” ...more

4/13/2015 - Bank Accounts Criminal Penalties DOJ Forfeiture IRS Tax Structuring White Collar Crimes

DOJ Announces First Swiss Bank to Reach Resolution Under Swiss Bank Program

Today the Justice Department announced that BSI SA of Lugano, Switzerland, one of the 10 largest private banks in Switzerland, is the first bank to reach a resolution under the Department of Justice’s Swiss Bank Program....more

3/31/2015 - Banks DOJ Non-Prosecution Agreements Switzerland

IRS Issues Further Revisions to Form 8938 Instructions

As part of the Foreign Account Tax Compliance Act (FATCA) passed by Congress in 2010, individual taxpayers are now required to report “specified foreign financial assets” on an information reporting form entitled Form 8938,...more

3/11/2015 - FATCA IRS Required Forms

FinCEN issues $1.5 million Penalty against Pennsylvania Bank for AML Violations

On February 26, 2015, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) issued an assessment of a civil money penalty totaling $1,500,000 against First National Community Bank (“FNCB”), which is...more

3/5/2015 - Civil Monetary Penalty Enforcement Actions FinCEN First National

IRS Announces That More Than 50,000 Have Enrolled In OVDP; Amnesty Program To Remain Open Indefinitely

Yesterday, the Internal Revenue Service unveiled its latest statistics on participation in its Offshore Voluntary Disclosure Program (OVDP), an amnesty program for taxpayers with undisclosed foreign bank accounts that has...more

1/30/2015 - Enrollment Enrollment Statistics Foreign Bank Accounts IRS OVDP

IRS Updates Streamlined Certification Forms; Narrative Explanation Is Mandatory

The Internal Revenue Service has recently updated the certification forms required to be filed by taxpayers seeking to avail themselves of the Streamlined Filing Compliance Procedures. The streamlined program was...more

1/16/2015 - FBAR Foreign Bank Accounts IRS

FATCA Update: More Guidance, IGAs, Forms Announced by Treasury and IRS

1. The United States announced the signing of two more Intergovernmental Agreements (IGAs) to implement FATCA. The latest IGAs were signed by the Netherlands and Curacao, and are dated December 18 and 16, respectively. Both...more

1/9/2015 - FATCA FFI Form W-9 Intergovernmental Agreements IRS Reporting Requirements U.S. Treasury

FATCA Update: Treasury Extends Time for Jurisdictions with Agreed-in-Substance IGAs to be Treated as if They Had an IGA in Effect

On December 1, 2014, Treasury and the IRS issued Announcement 2014-38 which provides relief to those countries which have reached FATCA Intergovernmental Agreements (IGAs) in substance, but have not signed such agreements....more

12/16/2014 - FATCA FFI Intergovernmental Agreements IRS U.S. Treasury

FATCA Update: Treasury Clarifies Obligations of Participating FFIs to Report Pre-Existing Accounts

Earlier today, Treasury and the IRS issued yet another correcting amendment to the previously-issued regulations implementing the Foreign Account Tax Compliance Act (FATCA). FATCA become effective on July 1, 2014, and...more

11/18/2014 - Amended Regulation FATCA FFI Foreign Bank Accounts IRS Reporting Requirements U.S. Treasury

IRS and DOJ Crack Down on Cash Reporting Violations

Federal law requires that anyone engaged in a trade or business who receives more than $10,000 in U.S. currency is required to file a Form 8300 (available here) with the Internal Revenue Service. Failure to do so can subject...more

11/4/2014 - Bank Accounts Banks DOJ IRS Reporting Requirements

Wegelin & Co. Account Holder Sentenced to Prison Term

On October 30, 2014, a federal judge in Manhattan handed down a three-month prison sentence to an individual who maintained more than $1 million in a secret bank account at Wegelin & Co. in Switzerland. Viktor Kordash, of...more

11/3/2014 - Criminal Prosecution FBAR Foreign Bank Accounts

IRS Clarifies Requirements for Streamlined Filing Procedures

On October 9, 2014, the Internal Revenue Service published additional guidance clarifying the requirements for participation in the Streamlined Filing Compliance Procedures. (See prior coverage of the new procedures...more

10/13/2014 - Filing Requirements IRS Offshore Funds OVDP

FATCA Notebook: Former IRS Chief, Taxpayer Advocate Criticize FATCA; Switzerland Moves Toward Greater Transparency

First, former acting IRS Commissioner Steven Miller speaks out against FATCA and suggests that the benefits of the new information reporting regime imposed by FATCA may not outweigh its costs. An article published by...more

10/10/2014 - Banks FATCA Foreign Bank Accounts Foreign Banks Intergovernmental Agreements IRS Popular Reporting Requirements Switzerland

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