Offshore Funds

News & Analysis as of

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

Business Litigation Alert: "The Panama Papers: Implications for Business"

The recent press around the "Panama Papers" leads to some serious considerations for businesses that engage outside counsel. As many of you know, the story centers on the leak of 11.5 million internal documents from the...more

Foreign Bank Account Reports Due June 30

U.S. Taxpayers who directly or indirectly controlled foreign financial accounts in 2015 are reminded that the deadline to file a Report of Foreign Financial Account (FBAR) FinCEN Form 114 is June 30. Taxpayers with unfiled...more

Panama Papers Fallout: A Push for Transparency and Regulatory Reform - Sanctions Also Levied Against Several Panama-Based...

In the wake of the "Panama Papers" – the unprecedented leak of 11.5 million files from a Panamanian law firm that revealed thousands of names and addresses linked to offshore companies – the White House has announced several...more

In Wake of the Panama Papers, Treasury Proposes New Reporting Requirements for Foreign-Owned Legal Entities

On May 10, 2016, the Treasury Department issued proposed regulations that, if approved, will require business entities formed in the United States that are owned by a single foreign person to obtain an employer identification...more

In Wake of Panama Papers Scandal Obama Calls for Stricter Bank Regulations, Tax Rules

In a news conference May 6, President Obama addressed recently announced rules and proposed regulations intended to help the U.S. fight tax evasion and other crimes connected to anonymous offshore companies and accounts. The...more

FinCEN Issues Final Rules for Customer Due Diligence Requirements

On May 11, 2016, the Financial Crimes Enforcement Network (“FinCEN”) issued the final version of its long-awaited “Customer Due Diligence Rules” under the Bank Secrecy Act. The final rules impose a new requirement on...more

FinCEN Unveils “Fifth Pillar” of Anti-Money Laundering Compliance

The idea that a “fifth pillar” of Anti-Money Laundering (“AML”) compliance – customer due diligence requiring U.S. banks, broker-dealers, mutual funds, commodity futures merchants, and introducing brokers (“covered financial...more

You Skipped OVDP, now the IRS has initiated an Audit

Since 2009, the Offshore Voluntary Disclosure Program (OVDP) has been available to Taxpayers who have foreign assets, foreign financial accounts, and foreign source income unreported for U.S. Income Tax and Bank Secrecy Act...more

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