Today the Justice Department announced that Société Générale Private Banking (Suisse) SA (SGPB-Suisse) and Berner Kantonalbank AG (BEKB), have reached resolutions under the department’s Swiss Bank Program. With today’s...more
Individuals and organizations with a financial interest in or signature authority over a foreign financial account, in which the aggregate value of the accounts exceeded $10,000 at any point in 2014, may need to file FinCEN...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
Today we celebrate innovation. On this day in 1873, a patent to create work pants reinforced with metal rivets was granted. This marked the birth of one of the world’s most famous garments: the blue jeans. Jacob Davis, a...more
The legacies of the global financial crisis continue to permeate the global landscape. In many ways, that unfortunate period in our history has forged a new era in the way in which we conduct business today. This is the case...more
The Future of the Department of Justice’s High Visibility Offshore Tax Evasion Initiative.
On August 29, 2013, the U.S. Department of Justice (“DOJ”) Tax Division announced the Program for Non-Prosecution Agreements...more
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 reported in this blog and elsewhere over the past few weeks, Raoul Weil was on trial in Florida for conspiring with U.S. taxpayers to hide their assets from the IRS through secret accounts held at UBS AG. Weil was the...more
In modern litigation there is often a strong possibility that obtaining interim relief from the court of the jurisdiction in which you are suing your opponent will not fully protect you against the dissipation by him of...more
The Department of Justice (DOJ) recently made demand of 106 Swiss banks for information and cooperation under the terms of proposed Non-prosecution agreements (NPA). Non-prosecution agreements were offered to Swiss banks in...more
On October 23, 2014, in Motorola Credit Corp. v. Standard Chartered Bank. No. 162, the New York Court of Appeals reaffirmed the continued vitality of New York’s “separate entity rule.” Under that rule, a judgment creditor...more
In the history of the old west when gun fighters survived a gun fight they might put a “notch” in their pistol as a badge of honor. Well the U.S. Department of Justice can put another notch in its weapon of choice, threat of...more
As you may have read, the Internal Revenue Service (“IRS”) recently announced changes to its offshore voluntary disclosure programs and announced new options for taxpayers to come into compliance with their U.S. tax...more
A scheme that some dual national taxpayers have used involves claiming exemption from foreign jurisdiction taxation because they are U.S. taxpayers and then not reporting the offshore account or its income as required by U.S....more
Last week, a federal jury in Miami found that Carl Zwerner had willfully failed to disclose his foreign bank account to the Treasury Department for calendar years 2004, 2005 and 2006. Zwerner now potentially owes the United...more
In this guide Harneys considers the scope of the Cayman Islands’ Confidential Relationships (Preservation) Law and the sanctions that apply to contraventions of it.
The Cayman Islands government considers the...more
Bloomberg BNA reported on May 9, 2014, that Swisspartners Group resolved a U.S. criminal tax probe by forfeiting $3.5 million and paying $900,000 in restitution for helping U.S. clients evade taxes with secret accounts. ...more
Any U.S. person who has a financial interest in or signature authority over one or more foreign financial accounts with an aggregate value over $10,000 (on any day of the year) must report the accounts to the Treasury...more
On April 30, 2014, Josef Dorig, 72, of Switzerland, pleaded guilty in federal district court in Alexandria, Virginia, to a single count of Klein conspiracy: conspiracy to defraud the U.S. by impairing and impeding the IRS....more
If you have unreported income from offshore accounts, now may be the best time to come forward and report those earnings; otherwise, you may be susceptible to criminal prosecution.
The IRS initially began this...more
FATCA is the new form of 30% U.S. withholding tax that is applied to U.S. source income, such as interest and dividends paid by U.S. companies, starting as early as July 1, 2014 for payments made to non-U.S. entities that are...more
Today, February 26, 2014, the Senate Permanent Subcommittee on Investigations will hold a hearing on offshore tax evasion titled “Offshore Tax Evasion: The Effort to Collect Unpaid Taxes on Billions in Hidden Offshore...more
The BVI Financial Investigation Agency (FIA) is presently reviewing the compliance arrangements of real estate agents throughout the jurisdiction to ensure they meet the requirements of the British Virgin Islands’ (BVI)...more
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
A database containing the names of more than 37,000 people with offshore entities and trusts in 10 tax haven jurisdictions was recently released online, providing a powerful investigative tool for regulators, journalists and...more
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