Read Tax Law news, alerts, and legal commentary from leading lawyers and law firms:
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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
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
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
On April 10, 2013, the White House released its proposed budget for fiscal year 2014. The budget contains significant tax proposals related to renewable energy, research and job creation, as well as numerous changes affecting...more
* Non-Enforcement Matters: - Legislation Reintroduced to Charge Investment Advisor User Fees - SEC Examination Program for Newly Registered Investment Advisers Reveals Common Areas of Concern - Recent...more
A New York federal grand jury recently indicted a Swiss lawyer and bank executive for their roles in allegedly assisting US citizens with hiding assets in Swiss bank accounts, allowing the US citizens to evade income taxes....more
Three times over the past four years, the IRS has given taxpayers with undisclosed offshore accounts the opportunity to come clean and avoid prosecution. While the most recent offer – the 2012 Offshore Voluntary Disclosure...more
In This Issue: House Ways & Means Committee Proposal Would Require Mark-to-Market for Derivatives and Modify Certain Other Tax Rules; After Months of Anticipation, Final FATCA Regulations Released; Congress Considers...more
In a recent report, the General Accounting Office (GAO) encourages the IRS to do more to uncover and pursue taxpayers who made quiet disclosures in regard to their non-U.S. accounts....more
In This Issue: - ILPA Guidelines Have Noticeable Impact - Extracting Tax Value in Debt Refinancings and Modifications - Private Equity and Venture Capital Investing in China: Exit Strategy and Circular 698 -...more
79 year-old Mary Estelle Curran received good new when she was sentenced for criminal tax evasion and failing to file reports of foreign bank accounts on UBS Swiss accounts she inherited from her husband....more
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