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"Government Enforcement: Aggressive Efforts Continue Around the Globe"

Government enforcement efforts in 2013 produced major settlements of matters relating to the global financial crisis, high-profile insider trading convictions, near-record amounts of FCPA settlements, and new pledges of...more

Fiduciary Liability and Offshore Assets

Fiduciaries, like trustees and conservators, may face personal liability for wrongful acts in administering estates. Among the liabilities that a fiduciary may face is to the IRS for wrongful distributions such as those made...more

So, You inherited an unreported offshore account, now what!

There may have been a time when inheriting an unreported offshore financial account was not problematic; but not today. The executor/trustee of the estate of the decedent has fiduciary responsibility to IRS and faces personal...more

Orrick's Financial Industry Week In Review - July 15, 2013

In This Issue: Financial Industry Developments; Rating Agency Developments; RMBS and Other Securities Litigation; and, European Financial Industry Developments. ...more

IRS Victory In FBAR Wilfulness Penalty Case

In an unpublished opinion, the Fourth Circuit Court of Appeals in U.S. v. Williams, reversed the district court’s holding that the taxpayer’s failure to file Form TD F 90-22.1 (“FBAR”) was not willful and in so holding, gave...more

France: Introduction of New Anti-Abuse Rules on the Tax Deductibility of Interest and other Financing Expenses

Until recently, private-equity investment funds and international corporate groups investing in France enjoyed a very favorable tax environment, including inter alia the benefit of both EU Directives and the double tax...more

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