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Alta Wind Wins Cash Grant Dispute in Court of Federal Claims – Awarded US$206 Million

Favorable decision clarifies the value of cash grants and investment tax credits for renewable energy projects. A large wind developer won a significant victory in the Court of Federal Claims on October 28 in a case that...more

Top 10 Foreign Bank Account Reporting (FBAR) Mistakes (And How to Fix Them)

While FBAR reporting rules are frequently misunderstood, US persons have several options to correct mistakes, before the government learns of the non-compliance. June 30th is the annual deadline for filing a Foreign...more

Foreign Banks and Bankers Face New Risks From Swiss Bank Amnesty

The first non-prosecution agreement signals expanded US tax enforcement opportunities at home and abroad. The US Department of Justice (DOJ) has announced the first non-prosecution agreement (NPA) with BSI, SA, (BSI)...more

Bandfield Confirms Aggressive FATCA Enforcement Tactics

On Sept. 9, 2014, in U.S v. Robert Bandfield et al., federal prosecutors in the Eastern District of New York announced the indictment of a U.S. citizen and others, including offshore corporate service providers (CSPs) and...more

FATCA Violation Underlies Latest US Tax and Securities Fraud Charges

Indictment demonstrates the strength of US law enforcement efforts to combat offshore fraud and is the first to charge a FATCA violation. On September 9, 2014, in US v. Robert Bandfield, et al., federal prosecutors in...more

First Circuit Liberalizes Tax Deductibility Standard of False Claims Act Settlements

Appellate court affirms $50 million tax refund to FCA defendant, holding that the “economic realities” of settlement payments determine whether they are compensatory. Civil False Claims Act (FCA) settlements, which...more

Beyond Switzerland: Preparing for the Fallout from FATCA and Other Global Transparency Initiatives

You have implemented FATCA; what comes next? Will your company be the next witness in a US tax investigation? Financial institutions around the world must now prepare to respond to anticipated inquiries and investigations as...more

IRS Eases Access to Offshore Voluntary Disclosure Programs

The changes give taxpayers who mistakenly failed to report foreign assets a simpler path back to tax compliance. On June 18, 2014, the Internal Revenue Service (IRS) announced major modifications to the terms of its...more

6/25/2014  /  FBAR , Income Taxes , IRS , OVDP , Tax Evasion

6 Reasons US Taxpayers Should Report Assets Held in Swiss Banks Soon

Initial success of DOJ Swiss bank amnesty program creates greater urgency for US taxpayers. On December 31, 2013, the window to apply for the US Department of Justice’s (DOJ) amnesty program closed for certain Swiss...more

9 Ways to Reduce the Risk of Worker Classification Disputes

The Patient Protection and Affordable Care Act (ACA) links the number of employees a business has to that business’s healthcare coverage responsibilities and penalties. As such, the ACA focuses new attention on the already...more

Crackdown on US Tax Evaders With Secret Offshore Accounts Leads to International Banking Reforms

Miriam Fisher, global Co-chair of the firm's Tax Controversy Practice, focuses her practice on federal tax controversy and litigation, including complex civil and criminal tax matters. Fisher spoke at the November 6, 2013...more

10 Facts About the Affordable Care Act and Worker Classification

Businesses subject to the Affordable Care Act’s “shared responsibility” provision must consider proper worker classification and its implications. Although the Patient Protection and Affordable Care Act, as amended...more

US Allows Swiss Banks With Undisclosed Accounts To Wipe the Slate Clean

United States Department of Justice issues further information on amnesty program for Swiss banks, including details on the selection of an Independent Examiner. On November 5, 2013, United States Department of Justice...more

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