Offshore Funds

The Offshore Voluntary Disclosure Program: A Brief History And Overview Of The Complexities Involved In Disclosing Foreign Assets

by CMCP - California Minority Counsel Program on 5/22/2013

The IRS and the Justice Department have increased their efforts regarding criminal investigation of international tax evasion. ...more

Indian American Neurosurgeon Sentenced to Probation for Unreported Offshore Bank Accounts

by Jay Nanavati | BakerHostetler on 5/21/2013

On February 1, 2013, the U.S. District Court for the Eastern District of Wisconsin sentenced Arvind Ahuja, a Milwaukee neurosurgeon, to serve three years of probation and to pay a fine of $350,000 following his conviction by...more

Government Runs Its Record to 4-0 in Compelling Production of Records of Offshore Bank Accounts

by Jay Nanavati | BakerHostetler on 5/21/2013

On February 7, 2013, the U.S. Court of Appeals for the Eleventh Circuit joined “the three of our sister circuits that have considered the same issue here about foreign financial account records and conclude that the...more

Supreme Court Settles Fifth Amendment Required Records Issue in Context of Offshore Bank Accounts

by Jay Nanavati | BakerHostetler on 5/21/2013

On May 13, 2013, the Supreme Court denied a taxpayer’s petition for certiorari regarding the Seventh Circuit’s August 27, 2012, decision applying the Required Records Exception to override the taxpayer’s Fifth Amendment...more

Tax Compliance Update: IRS Aggressively Pursues Foreign Banks; Offshore Voluntary Disclosure Program to Remain Open Indefinitely

by Fuerst Ittleman David & Joseph, PL on 5/15/2013

In our most recent discussion of the IRS’s Offshore Enforcement Initiatives, we discussed the John Doe Summons recently issued by the U.S. Department of Justice to Wells Fargo seeking information about First Caribbean...more

The Mergers & Acquisitions Review - Sixth Edition: Chapter 16: Cayman Islands

by Wendy Lee | Harney Westwood & Riegels on 5/14/2013

I OVERVIEW OF M&A ACTIVITY - According to a report of the Cayman Islands Economics and Statistics Office, the Islands’ economy began to recover from the economic downturn in 2011, with real gross domestic product...more

IRS Announces Information Sharing Agreement With Australia And The UK To Combat Tax Evasion

by David Gair | Looper Reed & McGraw, P.C. on 5/13/2013

The IRS continues to aggressively pursue offshore tax evasion. Another example of which is plan to share tax information with Australia and the United Kingdom....more

FATCA Compliance for Investment Fund Managers, Part Two

by Christopher Cawley, Nicola Lemay, Richard Schaul-Yoder | Foley Hoag LLP on 5/13/2013

This is the second in a series of Foley Advisers about FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers that will go into effect on January 1, 2014. Our prior installment described...more

IRS Issues “John Doe Summons” to Wells Fargo Seeking Identities of U.S. Taxpayers with Offshore Accounts at First Caribbean...

by Fuerst Ittleman David & Joseph, PL on 5/9/2013

Introduction - On April 30, 2013, the United States Department of Justice issued a “John Doe Internal Revenue Code” summons to Wells Fargo Bank, as a provider of correspondent bank services for Canadian Imperial Bank...more

OVDI Pre-Clearance Letters And Their Revocability

by Charles (Chuck) Rubin on 5/8/2013

The first step a taxpayer with undisclosed or unreported offshore accounts or assets undertakes in seeking to enter the Offshore Voluntary Disclosure Initiative (OVDI) is to apply for pre-clearance from the IRS Criminal...more

A Compilation of Enforcement and Non-Enforcement Actions - May 01, 2013

by Michael G. Dana, Peter D. Fetzer, Terry D. Nelson | Foley & Lardner LLP on 5/1/2013

* Non-Enforcement Matters: - Legislation Reintroduced to Charge Investment Advisor User Fees - SEC Examination Program for Newly Registered Investment Advisers Reveals Common Areas of Concern - Recent...more

Bank Leumi Snafu Jeopardizes DOJ-IRS Offshore Enforcement Initiatives

by Jeremy Temkin | Morvillo Abramowitz Grand Iason & Anello P.C.... on 5/1/2013

Three times over the past four years, the IRS has given taxpayers with undisclosed offshore accounts the opportunity to come clean and avoid prosecution. While the most recent offer – the 2012 Offshore Voluntary Disclosure...more

Superannuation Funds - Enhanced Investment Management Governance

by Jim Bulling, Daniel Knight, Gabrielle Palmieri | K&L Gates LLP on 4/26/2013

The Australian Government has been rolling out a series of significant regulatory reforms of the superannuation industry, many of which will commence in 2013. These reforms are fundamentally designed to enhance the prudential...more

FATCA Compliance for Investment Fund Managers Part One

by Christopher Cawley, Nicola Lemay, Richard Schaul-Yoder | Foley Hoag LLP on 4/2/2013

U.S. Funds with Only U.S. Investors - FATCA, the new U.S. tax regime designed to combat offshore tax evasion by U.S. taxpayers, will go into effect on January 1, 2014. As a fund manager, you will be required to ensure...more

The 50% FBAR Penalty, Are you at Risk?

by Sanford Millar on 4/1/2013

June 30 is the deadline for U.S. taxpayers, (including resident aliens) to timely report foreign financial accounts for the year ending 2012. The report form (TD 90-22.1) known as an FBAR is due if a U.S. taxpayer has control...more

Instant Messaging: “Vote-A-Rama” Provides Rare Insight into Tax Reform

by Mary Burke Baker, Michael W. Evans, Andrés Gil, Karishma Shah Page, Ryan J. Severson | K&L Gates LLP on 3/29/2013

By a vote of 50-49, the Senate passed its FY14 budget resolution (S. Con. Res. 8) at 5:00 a.m. last Saturday – the first time the Senate has passed a budget resolution in four years. The budget resolution is significant in...more

Tax Law Blog: The IRS is Airing its Dirty Laundry

by Jana M. Luttenegger | Davis Brown Law Firm on 3/29/2013

Unfortunately there is not a sci-fi theme video to spread the word on the Dirty Dozen (though there is a short YouTube video on the topic). Here are the most common tax scams the IRS wants you to be aware of during tax...more

Tax Communiqué: Highlights from the Budget 2013

by Heenan Blaikie LLP on 3/22/2013

Budget 2013 was tabled on March 21, 2013. Heenan Blaikie’s National Tax Group has prepared the following overview of some of the more significant tax-related measures....more

Asian Regulatory RoundUp - March 2013

by Angelyn Lim | Dechert LLP on 3/21/2013

In This Issue: - Greater China - Hong Kong - Taiwan - Singapore - India...more

In the Money – Puerto Rico Me Encanta! Puerto Rican Hedge Funds

by Gerald Nowotny on 3/18/2013

Overview - Every financial media outlet (including Bloomberg and the Wall Street Journal) in the last several weeks has run an article on the possibility of billionaire hedge fund manager becoming a Puerto Rican...more

Order Restored: Court hands down key judgment on BVI hedge fund insolvencies

by Phillip Kite, Ross Munro, Andrew Thorp | Harney Westwood & Riegels on 3/12/2013

Introduction - The Court of Appeal of the Eastern Caribbean Supreme Court on Monday, 11 March handed down an important ruling on the question of where investors stand in the “waterfall” of distributions in the...more

DOJ Revokes Some Pre-Clearances for Bank Leumi Depositors

by Sanford Millar on 3/11/2013

A recent press release should send a shudder to some voluntary disclosure participants. It should frighten some tax preparers and their clients....more

FATCA And Voluntary Disclosure

by Michael Volkov on 3/7/2013

The Internal Revenue Service has had success encouraging taxpayers with offshore accounts to disclose their foreign accounts and pay back taxes. In 2009 and 2011, the IRS announced the Offshore Voluntary Disclosure Program...more

Why California Needs a New Voluntary Disclosure Program.

by Sanford Millar on 3/5/2013

“Sometimes for taxpayers, who have serious tax non-compliance issues or may be facing international tax enforcement, the option of initiating a state voluntary disclosure contemporaneously with the making of a federal...more

Financial Services Tax – UK Update from Dechert’s Tax Group: Rule Changes Yield Mixed Blessings for UK Investors in Offshore Funds

by David Gubbay, Daniel Hawthorne, Mark Stapleton | Dechert LLP on 2/11/2013

UK investors in closely held offshore funds can be directly liable for tax if the fund makes a gain on an underlying asset even if the gain is reinvested by the fund and not distributed to the investor. There is also the...more

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The Offshore Voluntary Disclosure Program: A Brief History And Overview Of The Complexities Involved In Disclosing Foreign Assets

Indian American Neurosurgeon Sentenced to Probation for Unreported Offshore Bank Accounts

Government Runs Its Record to 4-0 in Compelling Production of Records of Offshore Bank Accounts

Supreme Court Settles Fifth Amendment Required Records Issue in Context of Offshore Bank Accounts

Tax Compliance Update: IRS Aggressively Pursues Foreign Banks; Offshore Voluntary Disclosure Program to Remain Open Indefinitely

The Mergers & Acquisitions Review - Sixth Edition: Chapter 16: Cayman Islands

IRS Announces Information Sharing Agreement With Australia And The UK To Combat Tax Evasion

FATCA Compliance for Investment Fund Managers, Part Two

IRS Issues “John Doe Summons” to Wells Fargo Seeking Identities of U.S. Taxpayers with Offshore Accounts at First Caribbean...

OVDI Pre-Clearance Letters And Their Revocability

A Compilation of Enforcement and Non-Enforcement Actions - May 01, 2013

Bank Leumi Snafu Jeopardizes DOJ-IRS Offshore Enforcement Initiatives

Superannuation Funds - Enhanced Investment Management Governance

FATCA Compliance for Investment Fund Managers Part One

The 50% FBAR Penalty, Are you at Risk?

Instant Messaging: “Vote-A-Rama” Provides Rare Insight into Tax Reform

Tax Law Blog: The IRS is Airing its Dirty Laundry

Tax Communiqué: Highlights from the Budget 2013

Asian Regulatory RoundUp - March 2013

In the Money – Puerto Rico Me Encanta! Puerto Rican Hedge Funds

Order Restored: Court hands down key judgment on BVI hedge fund insolvencies

DOJ Revokes Some Pre-Clearances for Bank Leumi Depositors

FATCA And Voluntary Disclosure

Why California Needs a New Voluntary Disclosure Program.

Financial Services Tax – UK Update from Dechert’s Tax Group: Rule Changes Yield Mixed Blessings for UK Investors in Offshore Funds

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