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"Insights: Brexit"

On June 23, the UK electorate took the historic decision to leave the European Union, a process that has never been undertaken by any member state. While the vote itself does not trigger the process of exit from a legal...more

BREXIT: The UK Has Chosen To Leave The EU. What Next?

On 23 June 2016, the UK held a referendum in which the British people voted for the UK to leave the European Union. But what does this mean in practical terms? Who will BREXIT affect? Any business or financial...more

Dawn raids: How to prepare for, manage, and mitigate the increasing risk to multinational tech companies

Dawn raids and enforcement actions throughout Europe are becoming more and more prevalent. And increasingly, the targets of these raids are multinational tech companies with foreign headquarters, which through their global...more

Private Eyes They’re Watching You – Offshore Planning after the Panama Papers

Overview - If you have been reading my articles on JD Supra for a while, you will know that I love Afro-Cuban and Brazilian music. Nevertheless, the Hall and Oates song Private Eyes, is a more fitting song to describe...more

Swiss Cheese con Arroz con Pollo – Pondering Offshore Planning after the Panama Papers Scandal

Overview - It is an understatement to say that the state of affairs in the offshore landscape is in flux. The fallout from the recent scandal in Panama remains to be seen. The fall of the rich and famous may end up...more

Revised Property Transfer Tax Return Form Requests Additional Information About Hidden Buyers of New York City Real Estate

In February, the New York Times published an 8,000-word investigation into wealthy foreigners buying New York City real estate and taking advantage of U.S. laws that allow them to set up shell companies in order to obscure...more

National Security: Removing Barriers to Intra-Governmental Sharing of Information

The House of Commons in Canada is back in session. The federal Conservative Government wasted no time in introducing sweeping anti-terrorism bill (Bill C-51, the Anti-terrorism Act, 2015). I canvassed the legislative and...more

Washington Insight - May 2014

In This Issue: - Politics Drives the Agenda in Run-Up to the Midterms - An Insider's View: President Obama's Foreign Policy - The Anti-Energy Tax Incentives Caucus of the GOP - Trade Agenda Stagnant, For...more

Sport, Media, and Entertainment Intelligence - April 2014

Spanish Supreme Court orders Le Monde to pay damages to Real Madrid and FC Barcelona - The Spanish Supreme Court has ordered French daily newspaper Le Monde to pay damages of €300,000 to Real Madrid and €15,000 to FC...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

EU seeks to tighten the regulatory and fiscal net for digital companies

Introduction - The European Union (EU) has recently turned its attention to the thriving European digital economy. In two key areas, data protection and tax, the EU seeks to increase levels of regulation and impose new...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

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

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

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

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

Swiss To Help IRS Nab Tax Dodgers

After a much-publicized initial rejection by the Swiss lower house of parliament of an IRS-UBS deal in which the Swiss bank agreed to forward details of 4,450 of its American depositors suspected of tax evasion, the lawmakers...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

International Legal News Volume 4 Issue 1 - January 12, 2007


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