Offshore Funds

News & Analysis as of

Japan FSA Finalizes Amendments to the Article 63 Exemption

Final text of the Regulations with respect to the Amendments promulgated has been released as well as the Response to the public comments....more

DOJ’s Latest Offshore Tax Case Shows Expatriates Who Renounce U.S. Citizenship Not Immune From Prosecution

An individual residing in Switzerland since 2007, who apparently renounced his U.S. citizenship four years ago, was convicted today in federal court of one count of filing a false U.S. income tax return. According to a...more

Split-dollar Life Insurance – A Tax-Leveraged Derivative for Hedge Fund Managers

The Emergency Economic Stabilization Act of 2008 ended the not so discrete secret of hedge fund managers, the deferred compensation arrangement with their offshore funds or as the New York Times described, “an unlimited Super...more

Global Private Equity Newsletter - Winter 2016 Edition: Hong Kong Profits Tax Exemption for Private Equity Funds

The Inland Revenue (Amendment) (No.2) Ordinance 2015 (the “Amendment Ordinance”) came into effect on July 17, 2015, extending Hong Kong profits tax exemption to offshore private equity (“PE”) funds....more

Common Reporting Standards Come Into Effect For Many Offshore Funds on January 1, 2016

On January 1, 2016, the new standard for automatic exchange of information between tax authorities developed by the OECD (the “Common Reporting Standard”) becomes effective in the Cayman Islands, Bermuda, the British Virgin...more

Investment Insights - Top 10 Takeaways (November 2015)

Cybersecurity is more than a compliance issue, it is a business issue for all businesses, including investment advisers. What do your policies and procedures say and are you actively following them? How are your service...more

Offshore Accounts Still Focus of IRS Enforcement

The following Notice from the IRS reiterates the enforcement focus on offshore accounts. Anyone with an unreported offshore account needs to consult counsel and discuss, their compliance options under the "attorney-client...more

Internal Revenue Service Issues Stern Warning To Non-Compliant Taxpayers With Offshore Holdings

Just one day after the October 15 deadline for filing personal income tax returns on extension, the Internal Revenue Service issued a strongly-worded warning to non-compliant taxpayers: take action now to fix your problem, or...more

The Benefit of Establishing an Offshore Asset Protection Trust While the Coast is Clear

Offshore asset protection trusts avoid or diminish a number of creditor exposures that apply to such trusts organized in the U.S. High net worth individuals and persons involved in high liability exposure businesses and...more

Justice Department Focusing on Offshore Account

At a recent tax conference a senior Justice Department official reaffirmed the commitment of the U.S. Department of Justice to continue offshore enforcement efforts. As is widely reported the official stated...more

Bureau of Economic Analysis (BEA) Issues New Form BE-180 for U.S. Financial Services Providers Including Investment Advisers

Now that the dust has settled a little on the BE-10 benchmark survey responses, U.S. financial service providers, including investment advisers, should take note that the U.S. Bureau of Economic Analysis (the “BEA”) has...more

BEA Report May Need To Be Filed by Managers of Offshore Funds by November 1

The U.S. Bureau of Economic Analysis (the “BEA”) requires U.S. financial institutions to file a benchmark survey – the BE-180 – once every five years. Although the BE-180 survey is not new, the BEA recently revised its...more

INTERPOL and the tax man

A reader recently sent in the following questions: Can you tell me would the IRS issue a diffusion notice in a civil tax audit involving offshore banking? Would Interpol even accept a diffusion notice on a non criminal...more

Justice Department Announces That Three More Swiss Banks Reach Agreements Over Tax Evasion Claims

On July 30, 2015, the Justice Department’s Tax Division announced that three more Swiss banks — PKB Privatbank AG, Falcon Private Bank AG and Credito Privato Commerciale in liquidazione SA (CPC) – have cut deals with the U.S....more

When the Fifth Amendment Privilege Doesn't Work-Tax Cases

A recent decision of the Third Circuit Court of Appeals illustrates the futility of expecting that the Fifth Amendment Privilege Against Self-incrimination will shield taxpayers from production of offshore financial records. ...more

Revamping U.S. Taxation of Multinational Corporations?

The Obama administration and top lawmakers are in discussions regarding a potential overhaul of how the United States taxes U.S. multinational corporations. Topics under consideration include eliminating the U.S. approach of...more

Global Insight - Restructuring e-Newsletter: Oil and gas sector distress - UK and US perspectives; PRC real estate restructuring;...

A UK perspective on oil price volatility - industry impact and legal considerations - The dramatic decrease in the price of crude oil over the last eleven months has had ramifications across the globe. With prices...more

Cross-Border Activities: Benefits of Filing “Protective” Returns

With the increasing focus by the Internal Revenue Service (IRS) on offshore activities, it is important to understand the tax return and information return filing obligations that may be associated with such activities....more

BakerHostetler Attorneys James Mastracchio and Jay Nanavati Discuss Global Tax Enforcement [Video]

Global tax enforcement is the number one priority of the U.S. authorities, and they are using their resources and tools in unprecedented ways to ensure that those who intentionally evade taxes are identified and brought to...more

Global Tax Enforcement in 2015: What You Need to Know

Tax fraud occurs on a considerable scale that can exceed law enforcement’s ability to detect and punish the conduct. This is true at both the federal and state levels. As of 2015, the Internal Revenue Service (“IRS”) and the...more

Is it US taxable income? Unintended consequences when US residents receive assets from their family’s foreign corporations

It is not uncommon for affluent families from certain countries to maintain offshore structures to hold a portion, and often times a significant portion, of their wealth. The reasons for holding assets outside of their...more

Tax Day Has Passed, But Don’t Forget June 30th!

Now that April 15th has passed, you might be thinking that you are done with tax filings for the year. But, if you have any foreign bank accounts or financial assets overseas, you may be required to file a Form 114 (commonly...more

BSI Account Holders Now Face 50 Percent Penalty On All Undisclosed Offshore Accounts

On Monday, March 30, 2015, the Department of Justice (the "Department") announced its first settlement under the Swiss Bank Program, potentially exposing thousands of U.S. taxpayers to a steep 50 percent penalty for failure...more

New York Restaurateur Pleads Guilty to Hiding Money in Swiss Accounts

On February 19, 2015, Georges Briguet, the owner of New York restaurant Le Perigord, pleaded guilty to one count of corruptly endeavoring to obstruct the IRS by concealing the existence of his Swiss bank accounts. According...more

IRS Clarifies Requirements for Establishing Non-Willful Conduct in Offshore Disclosure Cases

Voluntary disclosure programs exist for taxpayers that are not in compliance with their tax and information reporting obligations with respect to foreign bank accounts and assets. The Internal Revenue Service (IRS) recently...more

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