Miriam Fisher

Miriam Fisher

Latham & Watkins LLP

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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

9/17/2014 - Enforcement Enforcement Actions FATCA International Tax Issues Offshore Funds Tax Evasion

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

9/16/2014 - Conspiracies Enforcement Actions FATCA FATCA Timeline Fraud Indictments Investment Adviser Money Laundering Offshore Companies Reporting Requirements Securities Fraud Tax Evasion Third-Party Service Provider

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

8/25/2014 - False Claims Act Income Taxes Settlement Tax Deductions

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

8/12/2014 - Banking Sector Banks Chief Compliance Officers DOJ Enforcement FACTA FATCA FFI Financial Institutions Government Investigations IRS OVDP Popular Transparency

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

2/4/2014 - DOJ FATCA Foreign Banks Non-Prosecution Agreements Offshore Banks OVDP Reporting Requirements Tax Amnesty Tax Evasion

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

1/23/2014 - Affordable Care Act Classification Employer Mandates Healthcare Healthcare Reform

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

12/11/2013 - Bank Accounts Compliance DOJ Enforcement Actions IRS Offshore Funds Tax Evasion

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

11/18/2013 - Affordable Care Act Classification Employer Liability Issues ERISA Full-Time Employees Misclassification

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

11/8/2013 - Banks DOJ Enforcement Foreign Bank Accounts Foreign Banks Tax Evasion

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