Tax Law, Finance & Banking, International Law & Trade

The Offshore Voluntary Disclosure Program: A Brief History And Overview Of The Complexities Involved In Disclosing Foreign Assets

by CMCP - California Minority Counsel Program on 5/22/2013

The IRS and the Justice Department have increased their efforts regarding criminal investigation of international tax evasion. ...more

HM Treasury Rethinks the UK Tax Treatment of Fee Rebates

by David Gubbay, Daniel Hawthorne, Mark Stapleton | Dechert LLP on 5/22/2013

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

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

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

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

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

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

UAE Launches New Financial Free Zone in Abu Dhabi

by Natalie Boyd, Amr Jaghoub, Simon Mabin | K&L Gates LLP on 5/9/2013

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

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

by Alan S. Kaplinsky, Jeremy T. Rosenblum, Mercedes Kelley Tunstall | Ballard Spahr LLP on 5/8/2013

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

OVDI Pre-Clearance Letters And Their Revocability

by Charles (Chuck) Rubin on 5/8/2013

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

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

by Steven Bortnick | Pepper Hamilton LLP on 5/7/2013

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

A Tax Opinion CAn Protect EB-5 VISA Status.

by Sanford Millar on 5/7/2013

An EB-5 Visa is known as an "investor" visa. The following is an explanation of the EB-5 program...more

Foreign Account Tax Compliance Act (FATCA) Registration

by Darren Mills | Berkeley Research Group, LLC on 5/6/2013

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

Legal Alert: FATCA NFFE Rules Subject Non-U.S. P&C Insurers and Reinsurers to Burdensome Reporting Requirements

by Dennis Allen, Thomas A. Gick, Saren Goldner, Jeffrey Mace, Michael Miles, William Pauls, M. Kristan Rizzolo, Christopher Schoen, Linda Sciuto, W. Mark Smith, Carol Tello, more +William Walderman, P. Bruce Wright | Sutherland Asbill & Brennan LLP on 5/6/2013

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

TRANSACTIONAL: Corporate/London: UK BUDGET 2013: The UK Government announces tax and other initiatives to support shale gas...

by King & Spalding on 5/6/2013

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

CFPB Modifies Foreign Remittance Rules And Sets New Effective Date

by Joseph D. Simon | Cullen and Dykman LLP on 5/6/2013

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

BVI, Cayman in discussions with UK government

by Peter Tarn | Harney Westwood & Riegels on 5/6/2013

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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Tax Law › Finance & Banking › International Law & Trade

The Offshore Voluntary Disclosure Program: A Brief History And Overview Of The Complexities Involved In Disclosing Foreign Assets

HM Treasury Rethinks the UK Tax Treatment of Fee Rebates

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

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

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

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

FATCA Compliance for Investment Fund Managers, Part Two

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

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.

Foreign Account Tax Compliance Act (FATCA) Registration

Legal Alert: FATCA NFFE Rules Subject Non-U.S. P&C Insurers and Reinsurers to Burdensome Reporting Requirements

TRANSACTIONAL: Corporate/London: UK BUDGET 2013: The UK Government announces tax and other initiatives to support shale gas...

CFPB Modifies Foreign Remittance Rules And Sets New Effective Date

BVI, Cayman in discussions with UK government

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