Read Tax Law news, alerts, and legal commentary from leading lawyers and law firms:
Selling Privately Held Businesses – Interview with Stephen Gulotta, Managing Member, Mintz Levin's New York Office
Lauryn Hill's Tax Evasion a 'Battle for Survival': Lawyer
Bill on Bankruptcy: The Market's Unquenchable Thirst for Junk
Hot Topics for Waste-to-Energy Investors and Developers
Monitor Thy Drink: Alcohol Import Regulations Under the TTB (Alcohol and Tobacco Tax and Trade Bureau)
Corporate Law Report: Workplace Romances, FMLA Changes, California Tax News, and More
The Corporate Law Report: First-to-File Patents, Hiring for Cultural Fit, Roth Conversions Post-Fiscal Cliff, and Global Corporate Insights
Will The Debt Ceiling Standoff End Up In Court?
Corporate Law Report - Office Party Holiday Risks, Human Trafficking, the Fiscal Cliff, More
Micah Green on U.S. Fiscal Policy
How Do We Pay For Lower Corp Tax Rates?
Polsinelli Shughart Election Analysis and Legal Insight
Why choose Bennett Jones for your Canadian Cross-Border Income Trust (CBIT)?
What are the tax benefits of a Canadian Cross-Border Income Trust (CBIT)?
Why choose Canada for a Cross-Border Income Trust (CBIT)?
What is a Canadian Cross-Border Income Trust (CBIT)?
Bill on Bankruptcy: Solyndra, Lehman, MF Global, ATP Oil, LSP Energy, Want Ads
Should you Opt-Out of the Voluntary Disclosure Program?
Weekly Brief: CFPB, Legal Fees & Hashtag Hijackers
Cost of Voluntry Asset Disclosure Program
When you get pulled over by the police while driving, the best way to handle is to be pleasant and not be argumentative. You listen to the officer as to why he pulled over. Being belligerent and non-cooperative will only lead...more
In This Issue:
- The true cost of fines: Bills would address tax break for corporate fines
- Senate approves new protection for criminal antitrust whistleblowers
- Justice Department sinks ex-Navy...more
The recently announced voluntary bank disclosure program between Switzerland and the US offers worried Swiss banks the possibility of peace of mind from future prosecution. The question now confronting Swiss banks is whether...more
According to statistics compiled by Jack A. Townsend, author of the Federal Tax Crimes Blog, nearly 130 individuals have been charged with maintaining and failing to report offshore bank accounts, or enabling those who do. ...more
On November 5, 2013 the Department of Justice issued a letter of explanation to Swiss banks. A portion of the warning is restated:
“Each eligible Swiss bank should carefully weigh the benefits of coming forward, and...more
Tax Analysts Tax Notes reports that the IRS Small Business/Self-Employed Division's special enforcement program (SEP) will soon begin examining U.S. taxpayers suspected of holding undeclared accounts in Indian banks. An IRS...more
On November 7, 2013, United States District Judge Kimba M. Wood of the Southern District of New York, granted authorization to the IRS to issue John Doe summonses to Bank of New York Mellon and Citibank requiring those banks...more
Individuals with previously undisclosed foreign assets and/or income have a variety of options to become compliant with the IRS, with two avenues for resolution being the most common: Qualified Quiet Disclosure and the...more
Tax Analysts Tax Notes reports that on November 6, 2013, Judge Timothy S. Black of the Southern District of Ohio permanently shut down Instant Tax Service, which claims to be the fourth largest tax return preparation firm in...more
The U.S. Department of Justice (DOJ) offer of non-prosecution agreements to certain Swiss banks expires December 31, 2013. Swiss banks who know or suspect that they have violated U.S. law, but who are not currently the...more
The Chicago Tribune reports that U.S. authorities are seeking information from Citigroup Inc.’s Citibank NA and Bank of New York Mellon Corp to uncover the identities of U.S. citizens who may have been hiding money in Swiss...more
Tax Analysts Tax Notes reports that Potomac, Maryland, attorney George Nelson Smith pleaded guilty on November 1, 2013 to filing a false tax return and failing to file a tax return. According to his plea agreement, Smith is...more
Tax Analysts Tax Notes is reporting that David Raminfard of Los Angeles pleaded guilty on November 4, 2013, in federal court to one count of conspiracy to defraud the United States (Klein conspiracy). ...more
In this issue:
- Swiss Bank Settlement Dilemma
- District Court Upholds STARS Transaction Ruling Payment Is Included in Pre-Tax Profit
- Court of Federal Claims Holds for Government in BB&T STARS...more
There are a lot of ways to get into hot water with state and federal revenue regulators. But, in my experience, three mistakes are most common.
In what is becoming an increasingly used attack vehicle, the Department of Justice (DoJ) is using the “required records doctrine” to compel taxpayer’s to produce what may be incriminating evidence of ownership or control of...more
- The IRS has signaled its intent to prosecute more small businesses for relatively low-value tax violations.
- In doing so, the IRS has increased its reliance on data-driven analyses of the...more
In This Issue:
- Small businesses beware: IRS deploys “big data” to scrutinize cash transactions
- Google’s scanning of emails may constitute wiretapping: Federal District Court denies Google’s motion to dismiss...more
Tax Notes reports that private Swiss bank Bank Frey & Co. AG announced October 17 that it will cease operations, further fallout from the United States’ enforcement efforts against offshore banks generally and Swiss banks in...more
I have previously written on the “quiet disclosure” alternative for complying with U.S. offshore reporting requirements. Under this alternative, late filing taxpayers will not participate in the Offshore Voluntary Disclosure...more
On October 15, 2013 the Swiss signed the Multilateral Convention on Mutual Administrative Assistance in Tax Matters.
As provided in the press reports....more
Multiple outlets are reporting that on October 15, 2013, William Reed, a Nevada businessman, was sentenced to nine years in federal prison after pleading guilty to conspiracy to defraud the United States, tax evasion, and...more
The U.S. Department of Justice (“DOJ”) established a Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (the “Program”) on August 29, 2013. The Program is intended to facilitate a resolution with the...more
Despite the unsettled nature of federal enforcement of the federal criminal drug laws in the context of state medical marijuana laws, the Nevada Legislature enacted Senate Bill No. 374 during its recently completed 77th...more
At the most recent meeting of the Finance Ministers and Central Bank Governors on July 19 & 20, 2013 they said “We are committed to automatic exchange of information as the new, global standard and we fully support the OECD...more