Miriam Fisher

Miriam Fisher

Latham & Watkins LLP

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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

4/16/2015 - Banks BSI SA DOJ FATCA FFI Foreign Banks IRS Non-Prosecution Agreements OVDP Swiss Banks Tax Evasion

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

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