Offshore Funds

News & Analysis as of

OCAC Publishes Report on Voluntary Disclosure Program

The Offshore Compliance Advisory Committee (OCAC) has published its report on the CRA’s Voluntary Disclosure Program, the first of several anticipated OCAC reports in furtherance of the OCAC’s mandate to provide advice to the...more

Supplemental Update: The Impact of the U.S. Presidential Election on U.S.-Mexico Relations

CEO’s Executive Summary: On November 8, the people of the United States elected Donald J. Trump to be the 45th President of the United States. We write to share some preliminary reflections and analysis on how we view this...more

What Kind of Tax Changes Can We Expect From Trump's Presidency?

The tears have not yet dried for some, and the celebrating is not yet over for others, but let's turn our attention to taxes. With a Republican Congress and a Republican president, some measure of tax relief is a given. What...more

Looking over the edge of the Cliff - The Use of Pooled Income Funds to Reduce the Taxation of Offshore Repatriated Carried...

The addition of IRC Sec 457A effectively ended the ability of investment managers to defer the tax recognition of the carried interest in the investment manager’s offshore fund. Under IRC Sec 457A, hedge fund managers must...more

Good-Bye to Wyatt Earp and More on 1MDB

Wyatt Earp died this week. Not the original Wyatt Earp who died in 1929 but the Wyatt Earp of my lifetime, who was actor Hugh O’Brian. O’Brien portrayed Earp in the long running television series Wyatt Earp which ran in the...more

Thinking About Renouncing Your U.S. Citizenship?

If you are U.S. citizen residing in Canada who is considering renouncing U.S. citizenship, in all likelihood you will have to wait well into calendar year 2017 to be given the opportunity to do so. In 2015, a record...more

Customer Due Diligence in the Post-Panama Papers Era

Sometimes it takes a scandal to advance a policy or law enforcement cause. The Panama Papers scandal has given new life to financial regulators around the world who seek to impose customer due diligence requirements on banks...more

Vineyard Wind offshore project changes hands

Danish fund management company Copenhagen Infrastructure Partnershas acquired Offshore MW LLC, the holder of an offshore wind energy lease issued by the U.S. Bureau of Ocean Energy Management over an area south of...more

Offshore Enforcement Remains Top Priority of DOJ

Principal Deputy Assistant Attorney General Caroline D. Ciraolo delivers remarks regarding the tax division's offshore tax enforcement efforts at the Panama Bankers Association Anti-Money-Laundering Conference...more

SEC Halts Scheme By IM Who Bilked Off-Shore Investment Manager

It can happen to anybody. The SEC has brought what seems like an almost endless string of investment fund and offering fraud actions. Typically small, unsophisticated investors, often known to the fraudster, are targeted with...more

Do not break the trust after a trust is created - The law on concurrence examined

Dentons Rodyk acted for Mdm Harianty Wibawa, the settlor of an offshore discretionary trust which has a value exceeding US$45 million (taking into account distributions of some US$10 million). One of the beneficiaries and the...more

Will the Panama Papers Lead to Criminal Charges Against U.S. Taxpayers?

The International Consortium of Investigative Journalists (ICIJ), collaborating with German newspaper Süddeutsche Zeitung, in spring 2016 began leaking approximately 11 million internal documents obtained without permission...more

CRA Provides OTIP Update

The CRA’s Offshore Tax Informant Program (OTIP) was launched in January 2014. From the CRA’s webpage describing the program: Launched as part of the Canada Revenue Agency’s (CRA) efforts to fight international tax...more

The Administrative Procedure Act - Challenging FBAR Penalties

Over the past 10 years, thousands of U.S. taxpayers with a wide variety of circumstances have been forced to pay extraordinarily high penalties for failure to disclose foreign bank accounts. For years, tax experts said that...more

¡Primera Convicción de FATCA!

El 9 de Mayo del 2016, el Departamento de Justicia (DOJ) anunció su primera convicción usando FATCA. Parece ser el principio de procesos penales por el DOJ contra violaciones aparentes o presuntas de los requisitos de...more

Streamline Procedure Risks: Are you really Non-willful?

According to reports in Tax Analysts there have been 54, 000 Offshore Voluntary Disclosure (OVDP) participants 30,000 Streamline Procedure filings. The Streamline Procedure filings are now the subject of intense Department...more

IRS and DOJ are Reviewing and Scrubbing Offshore Accounts Data to Build Civil and Criminal Cases

During the June 24, 2016 Tax Controversy Conference held at New York University, officials from both the Department of Justice (DOJ) and the Internal Revenue Service (IRS) emphasized their focus on analyzing the avalanche of...more

Wealth Management Update - July 2016

July Interest Rates for GRATs, Sales to Defective Grantor Trusts, Intra-Family Loans and Split Interest Charitable Trusts - The July § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and...more

Government Investigations: Use of the Financial Crimes Enforcement Network and Virtual Currency

Since 2009, the US Department of Justice has implemented an aggressive anti-tax evasion strategy that has changed by targeting tax havens that host financial intermediaries (i.e., banks) to the financial intermediaries...more

IRS Agrees to Increased Enforcement of IRS's Offshore Voluntary Disclosure Program

In a report issued to the Internal Revenue Service International Division and Criminal Division, the Treasury Inspector General for Tax Administration (TIGTA) found that taxpayers trying to avoid criminal charges and...more

What Attorneys Can Learn from History’s Largest Data Breach

On April 3, 2016, the public learned that millions of client documents from the Panamanian law firm and corporate services provider Mossack Fonseca & Co. (MF) had made their way to an international organization, the...more

¿Ha recibido una Carta FATCA?

Muchos Expatriados Estadounidenses están recibiendo Cartas FATCA de los bancos del extranjero alrededor del mundo. Los bancos están enviando estas cartas en anticipación al Reporte FATCA del IRS para reportar la información...more

“Spider Webs”, “Panama Papers” and IRS

IRS has asked involved U.S. taxpayers to come forward before IRS reads and dissects the “Panama Papers”. IRS will “plan how to use the huge trove of leaked documents to catch criminals — and urged Americans to come clean now...more

The Panama Papers and Shell Games – Part II

Today I conclude my exploration of some of the issues raised by Ryan Hubbs, a senior manager of fraud investigation and dispute services at Ernst & Young LLP (EY), in the 2014 Fraud Magazine article, entitled “Shell Games”....more

The Panama Papers and Shell Games, Part I

One of the more prescient authors I know is Ryan C. Hubbs, a senior manager of fraud investigation and dispute services at Ernst & Young LLP (EY), who, in 2014, wrote an article for Fraud Magazine entitled “Shell Games”. In...more

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