News & Analysis as of

Non-Prosecution Agreements Tax Evasion

McDermott Will & Emery

Despite Appeals Win, Google Agrees To Eur 1B Settlement To Avoid Criminal Prosecution

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The Paris Court of Appeal affirmed that Google Ireland does not have a French permanent establishment in a high-profile tax controversy over a double Irish arrangement. But with independent criminal proceedings for tax...more

Manatt, Phelps & Phillips, LLP

Corporate Investigations and White Collar Defense - July 2016

“Official Acts”—What They Are… and Are Not - Why it matters: On June 27, 2016, the Supreme Court decided McDonnell v. U.S., holding that, for purposes of the federal public corruption statutes, an “official act”...more

Blank Rome LLP

Swiss Banks Bank Zweiplus and Banca Stato Have Entered into Non-Prosecution Agreements under the DOJ’s Swiss Bank Program

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Two more Swiss banks have reached resolutions with the Justice Department under its Swiss Bank Program. Yesterday, DOJ announced that bank zweiplus ag (Bank Zweiplus) and Banca dello Stato del Cantone Ticino (Banca Stato)...more

Blank Rome LLP

Three More Swiss Banks Resolve Their Tax Issues with the United States

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The Justice Department continues to announce resolutions with banks under its previously-announced Swiss Bank Program. On August 6, DOJ announced the names of three more Swiss banks receiving non-prosecution agreements:...more

Blank Rome LLP

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

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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

Blank Rome LLP

Two More Banks Reach Resolutions Under Justice Department’s Swiss Bank Program

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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

Latham & Watkins LLP

Foreign Banks and Bankers Face New Risks From Swiss Bank Amnesty

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The first non-prosecution agreement signals expanded US tax enforcement opportunities at home and abroad. The US Department of Justice (DOJ) has announced the first non-prosecution agreement (NPA) with BSI, SA, (BSI)...more

Akerman LLP

DOJ Announces First Non-Prosecution Agreement Under the Swiss Bank Program

Akerman LLP on

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

Holland & Knight LLP

BSI Account Holders Now Face 50 Percent Penalty On All Undisclosed Offshore Accounts

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On Monday, March 30, 2015, the Department of Justice (the "Department") announced its first settlement under the Swiss Bank Program, potentially exposing thousands of U.S. taxpayers to a steep 50 percent penalty for failure...more

BakerHostetler

BSI Is First Bank to Reach Resolution in DOJ’s Program for Swiss Banks

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BSI of Lugano, Switzerland, became the first bank to earn a non-prosecution agreement under the U.S. DOJ’s Program for Swiss Banks, paying a penalty of $211 million. First announced on August 29, 2013, the program offered...more

Blank Rome LLP

DOJ Issues Further Guidance on Swiss Bank Program

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Recently the Justice Department’s Tax Division issued further “comments” regarding its “Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks.” In prior posts we have described this program designed to...more

Latham & Watkins LLP

6 Reasons US Taxpayers Should Report Assets Held in Swiss Banks Soon

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Initial success of DOJ Swiss bank amnesty program creates greater urgency for US taxpayers. On December 31, 2013, the window to apply for the US Department of Justice’s (DOJ) amnesty program closed for certain Swiss...more

Dechert LLP

U.S. Department of Justice Awaits Swiss Banks’ Voluntary Disclosure of Banking Activities

Dechert LLP on

The U.S. Department of Justice (“DOJ”) established a Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks (the “Program”) on August 29, 2013. The Program is intended to facilitate a resolution with the...more

BakerHostetler

U.S. DOJ Offers Landmark Non-Prosecution Deal for Swiss Banks

BakerHostetler on

On August 29, 2013, the U.S. Department of Justice announced a program, supported by the Swiss government, to encourage all Swiss banks to admit their role in U.S. tax evasion in exchange for non-prosecution agreements and...more

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