Matthew Lee

Matthew Lee

Blank Rome LLP

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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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