News & Analysis as of

Disclosure Requirements Tax Evasion

Proskauer - Tax Talks

Proposed Regulations Issued on Reporting Obligations for Basket Contract Transactions

Proskauer - Tax Talks on

On July 12, 2024, the U.S. Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued proposed regulations that would classify “basket contract transactions”, which are derivatives (i) with a term...more

Allen Barron, Inc.

What is the IRS Offshore Voluntary Disclosure Program?

Allen Barron, Inc. on

What is the IRS Offshore Voluntary Disclosure Program and who is it designed to help? What are the guidelines for voluntary disclosure to the IRS and who is eligible to apply? The IRS Offshore Voluntary Disclosure...more

Ankura

Failure to Prevent Fraud: Reasonable Procedures and Preparing Your Organization for the New Offense

Ankura on

An amendment to the Economic Crime and Corporate Transparency Bill (the Bill) has brought in the offense of failure to prevent fraud (Offense). Under the new Offense, an organization will be liable where a specified fraud...more

Stikeman Elliott LLP

Ontario’s New Transparency Register: Getting Your OBCA Corporation Ready for January 1, 2023

Stikeman Elliott LLP on

Under new rules in force as of January 1, 2023, private corporations incorporated or continued under Ontario’s Business Corporations Act (“OBCA”) will be required to maintain a register (“Transparency Register”) of...more

Dechert LLP

HMRC’s Implementation of EU Mandatory Tax Disclosure Rules

Dechert LLP on

HMRC has released a consultation document in respect of its draft regulations implementing the EU mandatory tax disclosure rules that will apply from 1 July 2020 to intermediaries and relevant taxpayers in relation to...more

Foodman CPAs & Advisors

Common Reporting Standard (CRS) Reporting Avoidance Game Is Over

The Common Reporting Standard (CRS) is a reality for over one hundred Jurisdictions during 2018. The Organization for Economic Co-operation and Development (OECD) has stated that there are potential and perceived loopholes...more

Burr & Forman

IRS Announces End to Foreign Bank Account Disclosure Program: What Can You Do Now If You Still Have Unreported Foreign Bank...

Burr & Forman on

The IRS recently announced it will be shutting down its successful Offshore Voluntary Disclosure Program (OVDP) for unreported foreign bank accounts and income. The program will end September 28, 2018. Under the OVDP, first...more

Foodman CPAs & Advisors

The OECD is focused on maintaining the integrity of the CRS

As of August 2017, 102 international Jurisdictions are committed to the implementation timelines of the Common Reporting Standard (CRS). There are 49 Jurisdictions that are committed to the first exchange during 2017 and 53...more

Hogan Lovells

Are you ready for the Criminal Finances Bill 2017?

Hogan Lovells on

In December 2016 we considered the changes proposed by the Criminal Finances Bill (the Bill) in "All change for money laundering regulation? - Impact for the private equity industry." On 27 April 2017, the Criminal Finances...more

Carlton Fields

Brazilian Voluntary Disclosure Program: The Cost of The Medicine for Contaminated Funds

Carlton Fields on

On January 14, a voluntary disclosure program, the Special Regime for Foreign Exchange and Tax Regularization (RERCT), was enacted in Brazil. It gives Brazilian residents an opportunity to voluntarily disclose unreported...more

Blank Rome LLP

Justice Department Announces That Three More Swiss Banks Reach Agreements Over Tax Evasion Claims

Blank Rome LLP on

On July 30, 2015, the Justice Department’s Tax Division announced that three more Swiss banks — PKB Privatbank AG, Falcon Private Bank AG and Credito Privato Commerciale in liquidazione SA (CPC) – have cut deals with the U.S....more

McDermott Will & Emery

International News: Focus on Compliance

McDermott Will & Emery on

In This Issue - Welcome to the final issue of International News for 2014. As regulatory oversight of companies—from Sarbanes Oxley and the Dodd-Frank Act to the Foreign Corrupt Practices Act and the UK Bribery...more

McDermott Will & Emery

France Tightens Disclosure Requirements for Large Companies, Particularly in Relation to Transfer Pricing

McDermott Will & Emery on

The Anti-Tax Evasion Act and the Finance Act 2014 have introduced an annual transfer pricing documentation filing obligation and new disclosure requirements for large companies....more

K&L Gates LLP

The Cloak of Invisibility for Foreign Accounts Is Rapidly Unraveling: IRS and Foreign Banks Are Clamping Down on U.S. Tax Evasion

K&L Gates LLP on

A global push for enhanced financial transparency means that United States owners of foreign accounts and assets will not be able to remain invisible forever. New rules and enhanced enforcement of existing rules will soon...more

CMCP - California Minority Counsel Program

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

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

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