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
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
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
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
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
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
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
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
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
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
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
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