US Expatriate Tax Planning - Part 2 - A Podcast with Janathan Allen
Foreign Bank Account Reporting and Employment Tax Enforcement: Ronn Owens interviews Steve Moskowitz
BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement
In this bulletin, we highlight two recent federal court cases in which U.S. taxpayers won major victories against the United States with respect to their obligations to report non-U.S. accounts on FinCEN Form 114 – Report of...more
The financial and humanitarian crisis in Lebanon continues to hit the headlines. Our commercial disputes team has been assisting English domiciled families with funds held in Lebanese banks to take expedited legal steps in...more
In a recent decision, the U.S. Court of Appeals for the D.C. Circuit unanimously affirmed a district court order compelling three Chinese banks (not currently identified) to produce financial records in response to subpoenas...more
The Justice Department revealed its latest offshore bank resolution by announcing that it had entered into a non-prosecution agreement with a Swiss asset management firm called Prime Partners. This means that Prime Partners...more
A United States citizen or resident that owns (or has signatory authority over) an account at a foreign bank with a value in excess of $10,000 annually must file a Report of Foreign Bank and Financial Account (or “FBAR”) with...more
On June 3, 2015, the Justice Department announced that two more Swiss banks, Rothschild Bank AG and Banca Credinvest SA, reached resolutions under the DOJ Swiss Bank Program. Yesterday’s announcement brings the total Swiss...more
On March 30, 2015, the U.S. Department of Justice (DOJ) announced that it reached the first non-prosecution agreement under the Swiss bank program with BSI, S.A. (BSI). BSI, one of Switzerland's ten largest banks, has agreed...more
First, former acting IRS Commissioner Steven Miller speaks out against FATCA and suggests that the benefits of the new information reporting regime imposed by FATCA may not outweigh its costs. An article published by...more
On Wednesday, May 28, 2014, a jury in Miami issued a verdict against a taxpayer for $2.2 million in fees, interest, and civil penalties for willfully failing to file foreign bank account reports (FBARs) for his Swiss bank...more
United States Department of Justice issues further information on amnesty program for Swiss banks, including details on the selection of an Independent Examiner. On November 5, 2013, United States Department of Justice...more
Bloomberg/BNA is reporting that the DOJ announced today a program for Swiss banks to reveal tax information in return for nonprosecution agreements. The U.S. Department of Justice announced a program Aug. 29 to get Swiss...more
June 30, 2013 is the filing due date for 2012 “FBARs,” also known as Form TD F 90-22.1, Report of Foreign Bank and Financial Accounts. If there is a non-willful failure to file, the penalties are up to $10,000. If there is...more