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The IRS and the Justice Department have increased their efforts regarding criminal investigation of international tax evasion. ...more
In a Written Ministerial Statement made in UK Parliament on 21 May 2013, Treasury Economic Secretary Sajid Javid MP announced the Treasury’s intention to make a crucial and very welcome clarification to the recent HMRC Brief...more
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
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
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
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
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
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
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
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
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
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
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
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
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
The federal government of the United Arab Emirates (“UAE”) has issued legislation establishing a new financial free zone in Abu Dhabi. The name of the new free zone, “Global Marketplace Abu Dhabi” (“GMAD”), serves as a...more
The Consumer Financial Protection Bureau has finalized revisions to its remittance transfers rule and set October 28, 2013, as the rule’s new effective date. While not entirely eliminating the requirement for remittance...more
The first step a taxpayer with undisclosed or unreported offshore accounts or assets undertakes in seeking to enter the Offshore Voluntary Disclosure Initiative (OVDI) is to apply for pre-clearance from the IRS Criminal...more
Investment funds that invest globally must deal with volatility in the currency in which they agree to invest. Investment funds entering into obligations to purchase stock in a currency other than the primary currency of the...more
An EB-5 Visa is known as an "investor" visa. The following is an explanation of the EB-5 program...more
Beginning on December 31, 2013, the qualified intermediary (QI), withholding foreign partnership (WP), and withholding foreign trusts (WT) will be subject to the requirements of a foreign financial institution (FFI). As a...more
The good news is that, under the recently released Foreign Account Tax Compliance Act (FATCA) regulations, most non-U.S. property and casualty (P&C) insurance and reinsurance companies will not be considered foreign financial...more
In March the UK Government delivered its Budget for 2013, announcing a number of tax and other initiatives designed to encourage investment in the exploitation of UK shale gas resources. The Department of Energy and Climate...more
The Consumer Financial Protection Bureau (“CFPB”) has revised its previously issued rules on foreign remittance transfers to ease some of the disclosure concerns raised by financial institutions. The revised rules, which are...more
The British Virgin Islands and the Cayman Islands are currently in dialog with the UK government on a number of issues related to the UK’s G8 economic agenda, including enhanced transparency and exchange of information for...more
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