Are Criminal Laws the Right Response to Revenge Porn?
Blecker: GM Recalls Show Need for Harsher Penalties for "Red Collar" Criminals
Jail Time for Revenge Porn Offenses?
How a Reluctance to Deport Pop Stars Strengthens US Immigration Policy
Zimmermann: Dewey Charges Send 'Warning' To Struggling Law Firms
Is Punishment Dead in America?
How to Avoid Corruption Risks in China
Hailey French’s Story – When millions barely cover the bills.
Building A Post-Recession Law Firm
Fine Tuning Your Anti Corruption Compliance Program
Corporate Compliance Policies – Interview with Bridget Rohde, Member, Mintz Levin
What to Do When the Government Comes Calling – Interview with Peter Chavkin, Member, Mintz Levin
Corporate Criminal Liability – Interview with Bridget Rohde, Member, Mintz Levin
Bill on Bankruptcy: Unprecedented Actions by Two District Judges
Bill on Bankruptcy: Sandbagging of a Federal District Judge
For Jeff Skilling, 'Enron Was His Life,' Lawyer Says
Bill on Bankruptcy: Versace Mansion Up for Sale, Casey Anthony
Spitzer "Disappointed" in Wall Street's Regulators
Is Edward Snowden a Whistleblower?
Are Political Intelligence Practice Groups Too Risky?
In this issue:
- Supreme Court Limits Taxpayer’s Ability to Examine the IRS at a Summons Enforcement Hearing
- Court Determines Tax Analysis not Protected by Attorney-Client Privilege and Work Product Doctrine...more
It has been just over five years since the Internal Revenue Service (“IRS”) offered the first of three offshore voluntary disclosure programs for individuals with undisclosed foreign financial accounts. Since the announcement...more
A scheme that some dual national taxpayers have used involves claiming exemption from foreign jurisdiction taxation because they are U.S. taxpayers and then not reporting the offshore account or its income as required by U.S....more
Authorities in the U.S. continue to crack down on foreign financial institutions that have allegedly aided U.S. taxpayers in evading their tax obligations. On May 19, 2014, Credit Suisse AG pled guilty to conspiracy to aid...more
Former DOJ Tax Division AAG Kathy Keneally warned on June 24, 2014, that taxpayers should think carefully before signing a certification of non-willfulness and entering the IRS’s new Streamlined Filing Compliance Procedures....more
The Eleventh Circuit Court of Appeals, which hears appeals from the federal district courts in Florida, Georgia, and Alabama, ruled earlier this month that in order to impose penalties under IRC § 6701, the government bears...more
On Wednesday, June 18, 2014 the Internal Revenue Service announced sweeping changes to its Offshore Voluntary Disclosure Programs, effective Tuesday, July 1, 2014. Some taxpayers are treated much more leniently under expanded...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
Most United States persons who have foreign financial accounts are aware that they must file an annual report to the Internal Revenue Service (IRS) with respect to these accounts. Less well known, however, is that individuals...more
On June 18, 2014, the IRS made significant changes to the procedures pursuant to which U.S. Persons can disclose any failure to timely file a Report of Foreign Bank and Financial Accounts (FBAR), and/or an international...more
As the old adage goes, appearances can be deceiving. Sometimes when you peel back the layers on an issue, you find out that everyone, even the Justice Department, can engage in “spin.”...more
On June 18, 2014 the Internal Revenue Service (“IRS”) announced a modification to the 2012 Offshore Voluntary Disclosure Program (“OVDP”). The 2014 OVDP is a continuation of the 2012 program with modified terms. The voluntary...more
On June 18, 2014, the Internal Revenue Service (IRS) announced major changes to its 2012 Offshore Voluntary Disclosure Program (OVDP) and streamlined procedures. The modifications provide new options to help both taxpayers...more
On June 18, 2014, the IRS announced major changes to the OVDP, including a major expansion of the so-called Streamlined Program and an increased penalties for taxpayers who held accounts at banks that are under criminal...more
The European Court of Human Rights takes a stand on the ne bis in idem principle intervening on the relationship between administrative and criminal violations involving identical facts. Two recent decisions give interesting...more
In a recent appearance before THE U.S. Conference for International Business the IRS Commissioner stated the following:
“One of the most exciting aspects of our current times is to see governments working...more
On May 9, 2014, a Florida doctor was sentenced to serve two years in prison and three years supervised release for conspiring to defraud the Internal Revenue Service (IRS). The doctor was found guilty of concealing millions...more
Remarks on Monday by John Koskinen, the Commissioner of Internal Revenue, indicate that the IRS is close to conceding to outside pressure to more clearly distinguish between Offshore Voluntary Disclosure Program (OVDP) filers...more
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
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
As widely reported in the financial press, Credit Suisse AG (“Credit Suisse”), a large Swiss bank that maintains a branch and other offices in the United States pleaded guilty to the felony of conspiracy to aid tax evasion by...more
On May 19, the DOJ announced that a Swiss bank pleaded guilty and entered into agreements with federal and state regulators to resolve a multi-year investigation into the bank’s alleged conspiracy to assist U.S. taxpayers in...more
U.S. citizens and residents with unreported assets abroad may be feeling a steady increase of pressure these days. The July 1, 2014 effective date of the Foreign Assets Tax Compliance Act (FATCA) is looming. The number of...more
The Department of Justice has had enough. Banks and other financial institutions are not just on the radar screen – they are on the chopping block. One-by-one watch out – banks and other financial institutions are coming...more
In recent years the United States has increasingly amplified the pressure on United States persons to disclose assets they hold and income they earn abroad, especially relating to offshore financial accounts. Two prominent...more
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