Matthew Lee

Matthew Lee

Blank Rome LLP

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Foundation: April 2016 • V Ol. III, Issue 1

In yet another sign of its aggressive campaign to fight money laundering, the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) has trained its sights on the high-end real estate market in New York and...more

4/29/2016 - Anti-Money Laundering Bank Secrecy Act FinCEN Geographic Targeting Order PACE Real Estate Market

Tax Day Brings Barrage of Criminal Tax Charges and Warnings

With “Tax Day” upon us, the Justice Department’s Tax Division and U.S. Attorney’s Offices around the country have unleashed an avalanche of press releases warning would-be tax cheats of the severe criminal and civil...more

4/19/2016 - DOJ Income Taxes IRS Tax Evasion Tax Fraud

With April 18 Just Days Away, DOJ’s Tax Division Warns Would-Be Tax Cheats

With “Tax Day” fast approaching, the Justice Department’s Tax Division has issued a stern warning of its own to taxpayers thinking of cheating on their taxes. In a press release entitled “Justice Department Reminds Taxpayers...more

4/15/2016 - Criminal Prosecution DOJ IRS Tax Evasion Tax Fraud Tax Returns

As Tax Day Approaches, Justice Department and IRS Increase Intensity of Public Warnings

It is well-known that the Justice Department and Internal Revenue Service increase the frequency and intensity of their press releases announcing tax charges as “Tax Day” approaches (which is April 18 this year), so as to...more

4/12/2016 - Criminal Prosecution DOJ Identity Theft IRS Tax Evasion Tax Fraud Tax Refunds Tax Returns

Confirming That No Country Is “Off Limits,” DOJ Secures Guilty Pleas From 2 Cayman Islands Financial Institutions for Tax Evasion

In its first-ever conviction of a non-Swiss financial institution for tax evasion conspiracy, the Justice Department announced today that two Cayman Islands firms pleaded guilty in a U.S. court to conspiring to hide more than...more

3/10/2016 - Cayman Islands Civil Monetary Penalty Criminal Conspiracy Deferred Prosecution Agreements DOJ Financial Institutions Fraud Guilty Pleas IRS Restitution Tax Evasion

FATCA Update: Treasury Issues Long-Awaited Rules For Foreign Asset Reporting by Domestic Entities

The Treasury Department has finally issued regulations implementing the rules requiring domestic entities to annually disclose their foreign financial assets to the Internal Revenue Service. In 2010, as part of the enactment...more

2/25/2016 - Domestic Partnership FATCA Foreign Financial Assets Internal Revenue Code (IRC) IRS Reporting Requirements Trusts

Offshore Tax Enforcement Update: DOJ Announces Criminal Charges Against Bank Julius Baer

The U.S. government has filed criminal charges against another Swiss Bank — Bank Julius Baer — and simultaneously secured guilty pleas from two Julius Baer bankers who had been fugitives for the past five years. Pursuant to...more

2/9/2016 - Criminal Prosecution Deferred Prosecution Agreements DOJ IRS Swiss Banks

DOJ’s Latest Offshore Tax Case Shows Expatriates Who Renounce U.S. Citizenship Not Immune From Prosecution

An individual residing in Switzerland since 2007, who apparently renounced his U.S. citizenship four years ago, was convicted today in federal court of one count of filing a false U.S. income tax return. According to a...more

2/4/2016 - Expatriates Income Taxes Offshore Funds Swiss Banks Tax Evasion

DOJ Tax Division Chief Outlines Enforcement Priorities for 2016

In speech delivered on January 29, 2016, at the American Bar Association’s Tax Section Midyear Meeting, Acting Assistant Attorney General Caroline D. Ciraolo of the Justice Department’s Tax Division recapped her agency’s...more

2/2/2016 - Credit Suisse DOJ FBAR Foreign Financial Institutions (FFI) IRS OVDP Strategic Enforcement Plan UBS

Justice Department Opens 2016 Tax Season With Stern Warning to Taxpayers

The Internal Revenue Service announced that the 2016 individual income tax filing season opened on January 19, 2016, with more than 150 million returns expected to be filed. The IRS expects more than 70 percent of taxpayers...more

1/29/2016 - DOJ Income Taxes IRS Justice Department Tax Fraud

Justice Department Announces Historic Conclusion of Swiss Bank Program for Category 2 Institutions

The Justice Department achieved a historic milestone in its ground-breaking Swiss Bank Program with its announcement today of the final Category 2 bank resolution. The Justice Department executed its 80th and final agreement...more

1/28/2016 - Enforcement Actions Justice Department Offshore Banks Swiss Banks Tax Evasion

FinCEN Cracks Down on Real Estate Secrecy in Manhattan and Miami

In yet another indication of its aggressive efforts to fight money laundering, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) today issued another Geographic Targeting Order (GTO), this time targeting...more

1/13/2016 - Anti-Money Laundering FinCEN Geographic Targeting Order Real Estate Market Title Insurance

IRS Taxpayer Advocate Releases 2015 Annual Report to Congress

Today, the Internal Revenue Service’s National Taxpayer Advocate, Nina E. Olson, released her annual report to Congress. The Taxpayer Advocate Service (TAS) is an independent organization within the IRS that is dedicated to...more

1/6/2016 - Annual Reports Internal Revenue Code (IRC) IRS Tax Credits Tax Exempt Entities Tax Exemptions Tax Fraud

New Law Authorizes State Department to Revoke U.S. Passports of Tax Delinquents

This afternoon, President Obama signed into law a five-year, $305 billion highway funding bill that includes several controversial tax measures designed to help fund the legislation. One provision in the legislation...more

12/7/2015 - Barack Obama Internal Revenue Code (IRC) New Legislation Passports Tax Liability

IRS Criminal Investigation Annual Report Confirms Devastating Impact of Budget Cuts

Today the IRS Criminal Investigation Division released its annual report, summarizing its activities and accomplishments during fiscal year 2015. One of the key takeaways from the report is the devastating impact of budget...more

12/4/2015 - Annual Reports Budget Cuts Criminal Investigations Information Reports IRS

FinCEN Renews South Florida Geographic Targeting Order

The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has announced that it is extending its Geographic Targeting Order (GTO) focused on trade-based money laundering schemes in South Florida. When the GTO...more

10/27/2015 - Bank Secrecy Act Cartels Criminal Investigations FinCEN Geographic Targeting Order Illegal Drugs Money Laundering Patriot Act Reporting Requirements

Internal Revenue Service Issues Stern Warning To Non-Compliant Taxpayers With Offshore Holdings

Just one day after the October 15 deadline for filing personal income tax returns on extension, the Internal Revenue Service issued a strongly-worded warning to non-compliant taxpayers: take action now to fix your problem, or...more

10/19/2015 - FATCA Foreign Financial Institutions (FFI) Income Taxes Intergovernmental Agreements IRS Offshore Funds OVDP Swiss Banks Tax Evasion Tax Returns

Internal Revenue Service Begins Reciprocal Automatic Exchange of Tax Information Under FATCA IGAs

On October 2, 2015, the Internal Revenue Service announced that it had achieved a key milestone in implementation of the Foreign Account Tax Compliance Act (FATCA), a critical anti-tax evasion law passed by Congress in 2010...more

10/5/2015 - FATCA FFI Intergovernmental Agreements IRS Tax Evasion

FATCA Update: Treasury Relaxes September 30 Deadline for Model 1 IGA Jurisdictions to Exchange Tax Information

With less than two weeks remaining until many countries are required to exchange tax information with the U.S. pursuant to the Foreign Account Tax Compliance Act (FATCA), the U.S. has agreed to provide partner jurisdictions...more

9/21/2015 - Disclosure Requirements FATCA Financial Institutions Foreign Banks Foreign Jurisdictions Intergovernmental Agreements IRS Jurisdiction OVDP U.S. Treasury

FATCA Update: Institute of International Bankers Submits Comment Letter on FATCA Regulations

The Institute of International Bankers (IIB) has submitted a comment letter (available through Bloomberg BNA here; subscription required) to the Internal Revenue Service addressing various issues arising under the FATCA...more

9/21/2015 - Banks FATCA Financial Institutions Foreign Bank Accounts Investment Funds IRS Reporting Requirements

FATCA Update: IRS Issues Guidance Regarding Electronic Transmission of Forms W-8 and Updates Information Reporting Guides

The Internal Revenue Service has issued additional informal guidance regarding implementation of the Foreign Account Tax Compliance Act (FATCA). First, the IRS published a new “Frequently Asked Question” on its website...more

8/17/2015 - Electronic Data Transmissions FATCA Form W-8 Guidance Update Information Reports IRS

A Welcome Change: Congress Finally Conforms FBAR and Tax Return Filing Deadlines

Last week Congress passed, and the President signed, a bill entitled “The Surface Transportation and Veterans Health Care Choice Improvement Act of 2015.” While this legislation was primarily directed at extending federal...more

8/17/2015 - FBAR Federal Funding Filing Deadlines Foreign Bank Accounts Foreign Financial Accounts Income Taxes Surface Transportation and Veterans Health Care Choice Improvement Act

Ninth Circuit Reverses Tax Fraud Conviction Where Returns Were Not “Filed” With Internal Revenue Service

Yesterday the Ninth Circuit addressed the question of whether an individual can be convicted of filing false tax returns pursuant to 26 U.S.C. 7206(1) where the tax returns in question were tendered to an IRS agent during an...more

8/14/2015 - Audits Criminal Prosecution False Reporting Indictments IRS Reversal Tax Returns

OECD Releases Its Annual Tax Administration Report

On August 11, 2015, the Organisation for Economic Co-operation and Development (OECD) released its annual report addressing global tax administration. The OECD’s stated mission is to “promote policies that will improve the...more

8/13/2015 - Annual Reports International Tax Issues OECD Tax Policy Tax Revenues VAT

Three More Swiss Banks Resolve Their Tax Issues with the United States

The Justice Department continues to announce resolutions with banks under its previously-announced Swiss Bank Program. On August 6, DOJ announced the names of three more Swiss banks receiving non-prosecution agreements:...more

8/11/2015 - Banks DOJ Foreign Banks Non-Prosecution Agreements Swiss Banks Tax Evasion

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