Tax Privacy Finance & Banking

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The use of offshore SPVs in Shariah compliant transactions post-FATCA

In recent years and in the wake of the global financial crisis, international financial centers (IFCs) such as the British Virgin Islands (BVI) and the Cayman Islands (Cayman) have faced unprecedented political and regulatory...more

As Swiss Banking Becomes More Transparent, Americans with Undeclared Swiss Accounts Are Warned

In a move that was likely celebrated by United States governmental officials, Swiss banking secrecy eroded even further on Thursday, March 6, 2014. This is the day that parliament voted to provide foreign tax authorities with...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

Employment Law Commentary -- Volume 25, Issue 10 -- October 2013: California Legislative Update – It’s That Time of Year Again

While the federal government ground to a halt, the California Governor and Legislature have been busy voting on and signing a flurry of new legislation at the end of this year’s legislative session. The following is a survey...more

How Is The Canadian Government Doing On Protecting Personal Information In Its Operations?

In the last two weeks, the out-going Privacy Commissioner of Canada, Jennifer Stoddart, has released three reports that provide insight on the current state of Canada’s federal government’s protection of personal information...more

Washington Insight - August 2013

In This Issue: - Tax Reform: An Insider's View - A Deep Divide Over Corporate Tax Reform - The Current Economic State: An Insider's View - K&S Thought Leadership Event on the 3rd Anniverary of Dodd-Frank -...more

New IRS reporting rules raise privacy concerns

Originally published in the Daily Business Review on October 16, 2012. New IRS regulations that require banks to report non-U.S. taxpayers' bank deposit interest, which could then be shared with their home countries,...more

Will The IRS Report Non-U.S. Taxpayers’ Bank Deposit Interest To Foreign Governments?

Banks’ Reporting Requirements Raise Privacy Concerns - Effective January 1, 2013, U.S. financial institutions will be required to annually report bank deposit interest earned by non-U.S. residents to the IRS. Currently,...more

FBAR Scam

A recent article warns of a current email scam that attempts to trick recipients into sending bank account to the scammers. The email comes with “Report of Foreign Bank and Financial Accounts (FBAR)” in the heading, and...more

An Intergovernmental Approach to FATCA: US Treasury Issues Joint Statement From the United States, France, Germany, Italy, Spain...

On February 8, 2012, the Department of Treasury (the “Treasury”) and the Internal Revenue Service (the “Service”) issued proposed regulations under the Foreign Account Tax Compliance Act (“FATCA”). FATCA establishes a new US...more

Access Request for Advice to Minister Regarding Tax Amendments is Denied

In a recent decision, the Ontario Court of Appeal has permitted Ontario’s Minister of Finance to withhold draft policy option memos from disclosure in response to an access to information request. The requester sought records...more

Insight on Estate Planning - February/March 2012

In This Issue: - Does your trust need a protector? - Privacy, please! Keep family matters out of the public eye by avoiding probate - Consider a “stretch” to maximize and preserve IRA benefits - Estate Planning...more

Bank Secrecy May Be Dead In California!

Senate Bill 86 is on its way to the governor’s desk and he is likely to sign it in days. Why is this a big deal and how does SB 86 kill bank secrecy, well contained in the bill is new Revenue & Taxation code section 19266....more

California to Compel Banks to Disclose Delinquent Taxpayer Account Date

SB 86 just passed by the legislature includes a new provision for collection and enforcement of California tax liabilities. New Revenue and Taxation Code §19266 establishes the Financial Institutions Record Match System. The...more

Adozione modelli organizzativi ex-art. 6 D.Lgs 231/2001 Partecipate Comune di Pescara

La presente delibera è indirizzata a tutte le società partecipate dal Comune di Pescara, laddove il Comune ha una partecipazione totalitaria e/o di maggioranza nel capitale sociale ed i servizi svolti per conto...more

Summer’s Last Gasp: Notice 2010-60- Preliminary Guidance Under FATCA

INTRODUCTION Issued during the afternoon of the last Friday in August, Notice 2010-60 1 (the Notice) was soon emailed around the world even though it was evening in Europe and the middle of the night in Asia. Eagerly...more

North Carolina's Audit Practice Violates the First Amendment

On October 25, a U.S. District Court granted Amazon.com, LLC’s (Amazon) motion for summary judgment and held that the North Carolina Department of Revenue (Department) was not entitled to demand both product and customer...more

HSBC Next Tax Haven Bank Under Attack?

According to press reports a former employee of HSBC Private Bank in Geneva, Switzerland stole computerized account data on 80,000 accounts and delivered the information to French authorities. There is no indication how many...more

Tax Consequences for Customer Data Theft

Identity theft is not a trivial issue. The costs to our national, state and local economies, businesses and individual consumers are substantial. According to Forbes, the 2009 estimated cost of identity theft was $54 billion....more

Tax Consequences of Theft of Customer Data

Theft of customer data is not limited to identity theft, at least the kind where the thief uses stolen identities to defraud merchants, banks and destroy credit of consumers. An important example of what can happen when...more

Thinking About An Offshore Account - "Don't Ask, Don't Tell" Is Best Policy

Just "asking" about opening an offshore account might cause increased IRS scrutiny....more

IRS-UBS Deal Likely Brought to Swiss Voters

Last year, the IRS and Switzerland’s UBS Bank hammered out a deal where UBS agreed to disclose names of 4,450 American depositors suspected of stashing the cash in their UBS accounts to avoid paying taxes, against Swiss...more

It's Your Business- Spring 2010

IN THIS ISSUE: FTC to Begin Red Flags Rule Enforcement; Helping Employees without Hurting Your Business: Legal Considerations in Making Employee Loans; More than Good Manners-Personal Goodwill May Reduce Taxes. Please see...more

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