Offshore Funds

News & Analysis as of

Offshore Accounts? IRS is Watching

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

Offshore Fund-Related Litigation

Litigation against directors, officers and professional service providers, following the collapse of offshore funds and collective investment schemes such as Madoff and Weavering, continues to proceed in a variety of...more

As Swiss Banking Becomes More Transparent, Americans with Undeclared Swiss Accounts Are Warned

In a move that was likely celebrated by United States governmental officials, Swiss banking secrecy eroded even further on Thursday, March 6, 2014. This is the day that parliament voted to provide foreign tax authorities with...more

Senate Hearing Takes Aim on Offshore Tax Evasion

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

Who Is Next, Now That Swiss Banks Will Turn Over Account Data?

What do you do if your offshore account is at one of 14 Swiss banks currently under criminal investigation? What do you do if your offshore account is at one of the 106 Swiss banks that have entered into non-prosecution...more

Maine Legislators Take Aim At "Offshore Tax Havens"

Maine legislators have introduced legislation (LD 1120) to “close offshore tax loopholes.” The U.S. Public Interest Research Group’s report, "Closing the Billion Dollar Loophole," estimates that Maine could save $14 million...more

Release of Names With Interests in Offshore Entities: Ramifications

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

Courts are Consistently Ruling that the Act of Production Privilege Will Not Defeat Grand Jury Subpoenas Calling for Foreign Bank...

On December 13, 2013, the United States Court of Appeals for the Fourth Circuit issued its decision in United States of America v. Under Seal. On December 19, 2013, the U.S. Court of Appeals for the Second Circuit issued its...more

"Financial Institutions Wrestle With FATCA Implementation"

Over the past year, financial institutions have wrestled with the challenges presented by the U.S. Foreign Tax Compliance Act (FATCA). Originally scheduled to take effect in 2013, the U.S. Treasury Department and IRS have...more

FBAR Update

The Report of Foreign Bank and Financial Accounts (FBAR) can no longer be filed on TDF 90-22.1, and must be e-filed on Form 114. This alert summarizes developments involving FBAR e-filing and signature authority. They are...more

Will the U.S. Dept . of Justice Find Your Offshore Account?

At a recent tax conference a senior official of the U.S. Department of Justice DoJ) is reported to have said: “We’ll be looking for you”....more

Beanie Baby Creator Avoids Jail Time, Pays Steep Penalties for Undisclosed Offshore Accounts

On January 14, 2014, Beanie Baby creator H. Ty Warner was sentenced to two years of probation and 500 hours of community service resulting from his guilty plea for tax evasion. In addition, Warner was required to pay...more

New regulations extend BVI’s Approved Manager regime to qualifying funds from recognised jurisdictions

The British Virgin Islands introduced a ‘regulation light’ regime for investment managers on 10 December 2012 when the Investment Business (Approved Manager) Regulations 2012 (Old Regulations) came into force. During its...more

Guide to the British Virgin Islands Approved Manager Regime

This guide provides an overview of the British Virgin Islands’ Approved Manager regime. The regime came into effect on 10 December 2012 with the Investment Business (Approved Managers) Regulations, 2012 (the “Regulations”)...more

Financial Services Quarterly Report - Fourth Quarter 2013: UK Autumn Statement Brings Mixed Blessings

This year’s Autumn Statement delivered by the Chancellor of the Exchequer in Parliament on 5 December 2013, and the subsequent draft Finance Bill and H.M. Revenue & Customs (HMRC) and H.M. Treasury press releases of 10...more

Implications of the Foreign Account Tax Compliance Act, FATCA

Protecting domestic revenue is just one of several reasons why G-20 nations are cracking down on tax havens. Other reasons include their desire to track the international flow of funds used for terrorist activity or money...more

UK Finance Bill - Key Points

The UK Finance Bill 2014 was published in draft form on 10th December 2013 and the proposed legislation now enters a period of consultation, which will end on 4th February 2014. A full analysis of each and every measure...more

Crackdown on US Tax Evaders With Secret Offshore Accounts Leads to International Banking Reforms

Miriam Fisher, global Co-chair of the firm's Tax Controversy Practice, focuses her practice on federal tax controversy and litigation, including complex civil and criminal tax matters. Fisher spoke at the November 6, 2013...more

Chairman Baucus Issues a Discussion Draft on Tax Reform

Chairman Max Baucus has issued a discussion draft that offers some interesting and provocative proposals on corporate international tax reform. Designed to “reform international tax rules to spark economic growth, create...more

IRS Official Announces Crackdown on U.S. Taxpayers with Unreported Indian Accounts

Tax Analysts Tax Notes reports that the IRS Small Business/Self-Employed Division's special enforcement program (SEP) will soon begin examining U.S. taxpayers suspected of holding undeclared accounts in Indian banks. An IRS...more

Managing Offshore Holding Companies from China: Recent Case May Suggest Increased Tax Risk

As our readers know, foreign investments into the People’s Republic of China (“PRC”) are typically structured through one or more holding companies domiciled in offshore jurisdictions. Planned and implemented properly, an...more

Offshore Accounts Holders Have No Fifth Amendment Protections

In what is becoming an increasingly used attack vehicle, the Department of Justice (DoJ) is using the “required records doctrine” to compel taxpayer’s to produce what may be incriminating evidence of ownership or control of...more

Amendments to the Calculation Method for FDI Positions

Before offshore funds may be publicly offered and distributed in Taiwan, they must be registered with the Securities and Futures Bureau of the Financial Supervisory Commission (SFB). In order to be registered with the SFB,...more

Succession planning for your shares in a BVI company

Death and taxes, despite our best laid plans, are still with us. While trying to legally reduce your tax liability has become politically unacceptable and unfortunately, there is still not much we can do about death, there...more

US DOJ and Swiss government announce new voluntary disclosure program for Swiss banks

In recent years, the US Department of Justice has been aggressively investigating the use of bank accounts outside the US to evade tax. While emphasizing that its enforcement activities are and must remain global, the DOJ has...more

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