International Law & Trade, Tax Law

A Whiter Shade of Pale -- Building a Private Label Investment Program with Private Placement Life Insurance and Annuities

by Gerald Nowotny on 5/22/2013

Overview - Poor John Paulsen! Now that's an oxymoron! He has to be the most radioactive man on the Planet when it comes to tax planning. Everything he touches in business seems to be couched in subversive tax planning...more

What A Tax Attorney Can Do for You: Understand How Apple, Inc. Legally Does Not Pay Income Tax

by Anthony Diosdi | Moskowitz LLP on 5/22/2013

When Apple Inc., disclosed that it has not paid any corporate income tax over the past 4 years, it got the government’s attention. Hailed before the Senate, Apple is confident in their tax position because, it is legal. ...more

International Tax Compliance Update: Florida Couple Indicted for Failing to Report Offshore Bank Accounts as IRS Continues...

by Fuerst Ittleman David & Joseph, PL on 5/22/2013

In line with our recent coverage of the Internal Revenue Service’s initiatives to pursue illegal offshore tax havens, on May 16, 2013 a Florida couple – Drs. David Leon Fredrick and Patricia Lynn Hough – was indicted by a...more

Indian American Neurosurgeon Sentenced to Probation for Unreported Offshore Bank Accounts

by Jay Nanavati | BakerHostetler on 5/21/2013

On February 1, 2013, the U.S. District Court for the Eastern District of Wisconsin sentenced Arvind Ahuja, a Milwaukee neurosurgeon, to serve three years of probation and to pay a fine of $350,000 following his conviction by...more

Government Runs Its Record to 4-0 in Compelling Production of Records of Offshore Bank Accounts

by Jay Nanavati | BakerHostetler on 5/21/2013

On February 7, 2013, the U.S. Court of Appeals for the Eleventh Circuit joined “the three of our sister circuits that have considered the same issue here about foreign financial account records and conclude that the...more

Supreme Court Settles Fifth Amendment Required Records Issue in Context of Offshore Bank Accounts

by Jay Nanavati | BakerHostetler on 5/21/2013

On May 13, 2013, the Supreme Court denied a taxpayer’s petition for certiorari regarding the Seventh Circuit’s August 27, 2012, decision applying the Required Records Exception to override the taxpayer’s Fifth Amendment...more

FBAR Penalties and Estate Administration

by Sanford Millar on 5/20/2013

The death or disability of a taxpayer who has failed to timely file a Report of Foreign Bank or Financial Account (FBAR) can present difficult problems for fiduciaries like trustees, estate executors and conservators. The...more

FBAR Filing Due for Foreign Financial Account Holders

by Michael Cho | Berkeley Research Group, LLC on 5/18/2013

The 2012 Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts (FBAR), is due June 30, 2013. An employee or officer who has signature or other authority over, or financial interest in, foreign financial accounts is...more

Did Sergio Garcia Lose in Match Play with the IRS?

by Thomas Wechter | Duane Morris LLP on 5/17/2013

One of the most recognizable names in professional golf—although not the most winning name, having never won a major golf tournament—is Sergio Garcia. He is especially known for his tree shots, the latest of which was a...more

Budget 2013-14: The Government targets multinationals to recover from the GFC - Baker & McKenzie

by Dixon Hearder, Amrit MacIntyre, John Walker | Baker & McKenzie Australia on 5/15/2013

The Treasurer has delivered the 2013-14 Budget. With the Treasurer noting that almost $170 billion has been wiped off tax receipts since the GFC, a series of measures increasing the tax burden of multinationals, foreign...more

Tax Compliance Update: IRS Aggressively Pursues Foreign Banks; Offshore Voluntary Disclosure Program to Remain Open Indefinitely

by Fuerst Ittleman David & Joseph, PL on 5/15/2013

In our most recent discussion of the IRS’s Offshore Enforcement Initiatives, we discussed the John Doe Summons recently issued by the U.S. Department of Justice to Wells Fargo seeking information about First Caribbean...more

As Nonprofits Expand Their Global Reach, a Special Focus on Tax, Trademarks and the Foreign Corrupt Practices Act

by Charles Kolstad, Lindsay B. Meyer, Andrew D. Price, Jeffrey S. Tenenbaum | Venable LLP on 5/14/2013

In this presentation: - Introduction - Trademark/Brand Strategy and Protection - U.S. Foreign Corrupt Practices Act and Anti-Corruption - Cross-Border Tax Planning and Compliance Please see...more

IRS Announces Information Sharing Agreement With Australia And The UK To Combat Tax Evasion

by David Gair | Looper Reed & McGraw, P.C. on 5/13/2013

The IRS continues to aggressively pursue offshore tax evasion. Another example of which is plan to share tax information with Australia and the United Kingdom....more

FATCA Compliance for Investment Fund Managers, Part Two

by Christopher Cawley, Nicola Lemay, Richard Schaul-Yoder | Foley Hoag LLP on 5/13/2013

This is the second in a series of Foley Advisers about FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers that will go into effect on January 1, 2014. Our prior installment described...more

Editorial: Expatriating From U.S. To Puerto Rico May Make Sense For Some

by Jeffrey L. Rubinger | Bilzin Sumberg Baena Price & Axelrod LLP on 5/13/2013

The United States is one of only two countries in the world that taxes its citizens and residents on their worldwide income. Therefore, a U.S. taxpayer who earns only foreign-source income will be subject to U.S. federal...more

Verbatim: Global Compliance - Quarterly Newsletter: Spring 2013

by Orrick, Herrington & Sutcliffe LLP on 5/10/2013

We've highlighted a few notable developments in corporate governance law taking place this spring that may be of interest to you. For more information on any of the topics listed below, please contact us at...more

IRS Issues “John Doe Summons” to Wells Fargo Seeking Identities of U.S. Taxpayers with Offshore Accounts at First Caribbean...

by Fuerst Ittleman David & Joseph, PL on 5/9/2013

Introduction - On April 30, 2013, the United States Department of Justice issued a “John Doe Internal Revenue Code” summons to Wells Fargo Bank, as a provider of correspondent bank services for Canadian Imperial Bank...more

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International Law & Trade › Tax Law

A Whiter Shade of Pale -- Building a Private Label Investment Program with Private Placement Life Insurance and Annuities

What A Tax Attorney Can Do for You: Understand How Apple, Inc. Legally Does Not Pay Income Tax

International Tax Compliance Update: Florida Couple Indicted for Failing to Report Offshore Bank Accounts as IRS Continues...

Indian American Neurosurgeon Sentenced to Probation for Unreported Offshore Bank Accounts

Government Runs Its Record to 4-0 in Compelling Production of Records of Offshore Bank Accounts

Supreme Court Settles Fifth Amendment Required Records Issue in Context of Offshore Bank Accounts

FBAR Penalties and Estate Administration

FBAR Filing Due for Foreign Financial Account Holders

Did Sergio Garcia Lose in Match Play with the IRS?

Budget 2013-14: The Government targets multinationals to recover from the GFC - Baker & McKenzie

Tax Compliance Update: IRS Aggressively Pursues Foreign Banks; Offshore Voluntary Disclosure Program to Remain Open Indefinitely

As Nonprofits Expand Their Global Reach, a Special Focus on Tax, Trademarks and the Foreign Corrupt Practices Act

IRS Announces Information Sharing Agreement With Australia And The UK To Combat Tax Evasion

FATCA Compliance for Investment Fund Managers, Part Two

Editorial: Expatriating From U.S. To Puerto Rico May Make Sense For Some

Verbatim: Global Compliance - Quarterly Newsletter: Spring 2013

IRS Issues “John Doe Summons” to Wells Fargo Seeking Identities of U.S. Taxpayers with Offshore Accounts at First Caribbean...

UAE Launches New Financial Free Zone in Abu Dhabi

Franchising in Spain: 2012 in Review

CFPB Finalizes Revisions to Remittances Rule, Sets October 28 Effective Date

OVDI Pre-Clearance Letters And Their Revocability

Integrating Foreign Currency Hedges With Respect To Stock Purchase And Sale Agreements

A Tax Opinion CAn Protect EB-5 VISA Status.

U.S. to Cut Automotive Tariffs as Japan Enters TPP Talks

Foreign Account Tax Compliance Act (FATCA) Registration

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