Matthew Lee

Matthew Lee

Blank Rome LLP

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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

FinCEN Issues Geographic Targeting Order Focused on Money Laundering in L.A.’s Fashion District

In the latest development in a probe by U.S. Immigration and Customs Enforcement’s (ICE) Homeland Security Investigations (HSI) targeting alleged money laundering activities in Los Angeles’ garment trade, the Financial Crimes...more

10/3/2014 - Bank Secrecy Act Banking Sector Banks Cartels City of Los Angeles Enforcement Actions Fashion Industry FinCEN GTO ICE Illegal Drugs Mexico Money Laundering Popular Recordkeeping Requirements Reporting Requirements

TIGTA Releases Annual Report on IRS Compliance Trends

The Treasury Inspector General for Tax Administration (TIGTA) released its annual report on IRS compliance trends yesterday. The key takeaway from the report is TIGTA’s finding that the total amount of revenue received and...more

10/3/2014 - Compliance Enforcement Enforcement Actions IRS U.S. Treasury

FATCA Update: Brazil Signs IGA with U.S. and Treasury Releases More Guidance

On September 24, 2014, the government of Brazil announced it had signed an intergovernmental agreement with the United States as part of its adoption of the requirements of the Foreign Account Tax Compliance Act (FATCA). The...more

9/29/2014 - Brazil FATCA FFI Intergovernmental Agreements IRS U.S. Treasury

IRS Issues FATCA Fraud Alert

As part of its continuing efforts to combat the serious problem of identity theft, the Internal Revenue Service warned today that fraudsters have expanded their widening schemes to obtain identity information to foreign...more

9/25/2014 - FATCA FFI Foreign Bank Accounts Fraud Identity Theft IRS Offshore Funds Risk Alert

High Court Should Review Scope Of Crime-Fraud Exception

In Zolin, the Supreme Court determined that a party invoking the crime-fraud exception must make a threshold showing before a district court may review documented attorney-client communications on camera. The court settled on...more

9/4/2014 - Compliance Crime-Fraud Exception Criminal Prosecution FCPA SCOTUS United States v Zolin

The Crime-Fraud Exception: Open Questions for the Supreme Court

In Zolin, the Supreme Court determined that a party invoking the crime-fraud exception must make a threshold showing before a district court may review documented attorney-client communications in camera. The Court settled on...more

8/18/2014 - Attorney-Client Privilege Corruption Crime-Fraud Exception FCPA Fraud SCOTUS United States v Zolin

Second Circuit Finds Fourth Amendment Violation in Law Enforcement Retention of Computer Files Not Within Scope of Search Warrant

On June 17, 2014, the United States Court of Appeals for the Second Circuit issued a significant Fourth Amendment decision in United States v. Ganias. The decision is premised on the well-established notion that, because of...more

8/1/2014 - Electronically Stored Information Fourth Amendment Police Search Warrant Warrantless Searches

FATCA Update: Treasury and IRS Release Wave of Guidance as July 1 Approaches

With the July 1, 2014, implementation date of the Foreign Act Tax Compliance Act (FATCA) just two days away, the Treasury Department and the Internal Revenue Service have published long-awaited, and much anticipated, guidance...more

6/30/2014 - China FATCA FFI Final Guidance Intergovernmental Agreements IRS U.S. Treasury

Offshore Tax Enforcement Update: IRS Unveils Major Changes to Voluntary Disclosure Program

Since the 1970s, U.S. taxpayers with foreign banks accounts have been required to annually report their foreign bank account information to the Department of Treasury on a Report of Foreign Bank and Financial Accounts...more

6/30/2014 - Compliance FBAR Foreign Banks IRS Offshore Funds OVDP Tax Evasion Willful Violations

Offshore Tax Enforcement Update: Foreign Bank Account Disclosure Deadline Is June 2014

The annual deadline for filing FinCEN Form 114, Report of Foreign Bank and Financial Accounts (commonly known as the “FBAR” form), is fast-approaching. Any U.S. taxpayer with a financial interest in, or signature or other...more

6/26/2014 - FATCA FBAR FinCEN IRS Popular Tax Evasion

DOJ Issues Further Guidance on Swiss Bank Program

Recently the Justice Department’s Tax Division issued further “comments” regarding its “Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks.” In prior posts we have described this program designed to...more

6/9/2014 - Banks Cross-Border Cross-Border Transactions DOJ Foreign Banks Non-Prosecution Agreements Non-Target Letters Tax Evasion

IRS Commissioner Hints That OVDP Modifications Are in the Works

Since 2009, the Internal Revenue Service has offered three different amnesty programs for taxpayers with undeclared foreign bank accounts. These programs, the current version of which is entitled the Offshore Voluntary...more

6/6/2014 - Compliance FATCA FBAR International Tax Issues IRS Offshore Funds OVDP Tax Amnesty Tax Evasion Voluntary Disclosure

FBAR Penalty to Face Excessive Fines Clause Test

Last week, a federal jury in Miami found that Carl Zwerner had willfully failed to disclose his foreign bank account to the Treasury Department for calendar years 2004, 2005 and 2006. Zwerner now potentially owes the United...more

6/5/2014 - Bank Secrecy Act Banks Compliance Excessive Fines Clause FBAR Foreign Banks IRS Offshore Banks Offshore Funds SEC Tax Evasion

The Steady March Toward FATCA Implementation: 77,000 Financial Institutions Registered and Nearly 70 IGAs Reached

On June 2, 2014, the U.S. Treasury and the Internal Revenue Service announced further developments as the July 1 implementation date of the Foreign Account Tax Compliance Act (FATCA) quickly approaches....more

6/4/2014 - FATCA FATCA Timeline FFI IGAs IRS U.S. Treasury

Court’s Ruling Holding Corporate Officer Responsible for Trust Fund Recovery Penalty Illustrates Risk of Personal Liability for...

A district court in the Northern District of California has held that the officer of a now-defunct corporation is personally responsible for the Trust Fund Recovery Penalty based upon the company’s failure to collect, account...more

5/2/2014 - Corporate Officers Criminal Prosecution Employment Tax FICA Taxes IRS Joint and Several Liability Penalties Personal Liability Tax Fraud Withholding Tax

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