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State + Local Tax Insights -- Spring 2014

In This Issue: - Where’s Walden? Finding Protection under the Due Process Clause - Upcoming Speaking Engagements - CFCs and Subpart F Income in a California Water’s-Edge Election and What’s Wrong with the Apple...more

Courts are Consistently Ruling that the Act of Production Privilege Will Not Defeat Grand Jury Subpoenas Calling for Foreign Bank...

On December 13, 2013, the United States Court of Appeals for the Fourth Circuit issued its decision in United States of America v. Under Seal. On December 19, 2013, the U.S. Court of Appeals for the Second Circuit issued its...more

Fourth Circuit Court of Appeals Holds that Required Records Exception Trumps Fifth Amendment

On December 13, 2013, the Fourth Circuit Court of Appeals in United States v. Under Seal, 2013 U.S. App. LEXIS 24785 (4th Cir. Va. Dec. 13, 2013), held that the required records doctrine applies when the government subpoenas...more

Offshore Accounts Holders Have No Fifth Amendment Protections

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

IRS Seeking 50% x 4 Penalties In FBAR Nonreporting Case

Taxpayers are required to disclose their ownership interests in foreign bank and financial accounts by filing a Form TD F 90-22.1, ...more

Should Married Nonresident Aliens Elect Joint Return Status?

The recent decisions of the US Supreme Court, (in the Defense of Marriage Act and Proposition 8 cases) to strike down anti-gay marriage legislation may very well produce an increase in immigrant marriages. The actual number...more

Landmark US Supreme Court Decision May Extend US Tax Benefits to UK Civil Partners

On Wednesday, 26 June 2013, the US Supreme Court ruled that Section 3 of the Defense of Marriage Act (“DOMA”), which limits the definition of “marriage” to “a legal union between one man and one woman as husband and wife” and...more

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

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

World Trade Organization Rules Against Ontario’s “Buy Local” Program

The Province of Ontario has imposed a requirement that in order to participate in its feed in tariff program (FIT) for solar energy a project much source at least 60% of the solar project content from within the Province....more

District Court Decides FBAR Penalty Assessment Case - Both A Win For The Government & For OVDP Participants

Here at Moskowitz LLP, A Tax Law Firm based in San Francisco, CA, we have been following just how the Internal Revenue Service will collect FBAR penalties once imposed outside the scope of any Offshore Amnesty Program. ...more

PPL Corp. v. Commissioner of Internal Revenue

Brief For Southeastern Legal Foundation, CATO Institute, And Goldwater Institute As Amici Curiae In Support Of The Petition For...

An American energy company called PPL bought one of many state-owned British utilities privatized in the 1980s. In 1997, PPL thus became subject to the U.K.'s new "windfall tax," which was based in part on "profit-making...more

Senator Opposes Swiss Accounts Tax Treaty Change

Senator Rand Paul (R – Kentucky) opposes changes to the US-Swiss tax treaty that would effectively allow the US government more access to tax information connected to Swiss bank accounts of US citizens. Senator Paul stresses...more

Nigerian Sovereign Wealth Fund Law

The Nigerian Government has passed into law the Sovereign Investment Authority (Establishment, Etc.) Act 2011 to among other things establish a Nigerian Sovereign Investment Authority. This Authority is charged to receive,...more

No Fifth Amendment Privilege For Offshore Banking Records

Under the Fifth Amendment to the U.S. Constitution, a taxpayer may refuse to answer specific questions or produce specific records if it would violate his or her privilege against self-incrimination. In a recent appellate...more

DIREITO PORTUÁRIO (ADUANEIRO) SANCIONADOR

Presentation about some of the penalties existing in Brazilian Law against the port operators....more

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