Blecker: GM Recalls Show Need for Harsher Penalties for "Red Collar" Criminals
What Are the Drastic Ramifications of the New York State Anti-Money Laundering Actions and Penalty Enforcement?
Lessons Learned from the Parker Drilling DPA and Ralph Lauren NPA
The New Normal: Taking Responsibility for Your Vendors
Lessons Learned from the BizJet Executives FCPA Enforcement Actions
Crystal Ball Perspective: Will Healthcare Reform be Repealed if Romney Wins the Presidential Election?
Taxpayers who file a return late, make a late payment, or make a late tax deposit are subject to penalties. What is not known by most taxpayers, and a lot of tax practitioners, is that the IRS has a program to abate these...more
To moderate the draconian Foreign Bank and Financial Accounts (FBAR) violation penalties under Title 31 of the U.S. Code, the IRS just published guidance that significantly reduces willful and non-willful FBAR violations....more
Recently, the IRS released an internal memorandum to employees providing interim guidance on FBAR (Report of Foreign Bank and Financial Accounts) penalties. It reminds IRS examiners that when they assert FBAR penalties, the...more
A U.S. taxpayer with international holdings and interests may not be fully compliant with U.S. tax reporting obligations even though they have currently reported all foreign source income on their annual tax return, filed...more
Despite guidance from the Internal Revenue Service (“IRS”), the Department of Labor (“DOL”) and the Department of Health and Human Services (“HHS”) indicating the prohibition of the practice under the Affordable Care Act...more
Compliance with reporting obligations is always important for any employer, but the employer reporting requirements under the Affordable Care Act pack a significant penalty that makes compliance particularly...more
On June 18, 2014, the IRS announced sweeping changes to the 2012 Offshore Voluntary Disclosure Program (OVDP). Since that time, additional clarification on procedural requirements has been issued. Most recently, as of August...more
As you may have read, the Internal Revenue Service (“IRS”) recently announced changes to its offshore voluntary disclosure programs and announced new options for taxpayers to come into compliance with their U.S. tax...more
In a major change to the Offshore Voluntary Disclosure Program, the streamlined filing compliance procedures with their 5% penalty, has been opened up to non-willful violators that reside in the U.S. This is to be contrasted...more
On Wednesday, May 28, 2014, a jury in Miami issued a verdict against a taxpayer for $2.2 million in fees, interest, and civil penalties for willfully failing to file foreign bank account reports (FBARs) for his Swiss bank...more
Before the ink on the Affordable Care Act was dry, prudent employers were analyzing the law to identify ways to save money and avoid many of the punitive aspects of the law....more
A district court in the Northern District of California has held that the officer of a now-defunct corporation is personally responsible for the Trust Fund Recovery Penalty based upon the company’s failure to collect, account...more
The IRS recently released an FBAR Reference Guide, pertinent portions of which are reprinted below.
Who Must File the FBAR?
A United States person must file an FBAR if that person has a financial interest in or...more
Now that the IRS has issued final regulations under Section 4980H, the so-called “pay or play” provision of the Affordable Care Act, employers are deciding how to determine whether employees are full-time (30 hours or more a...more
Beginning January 1, 2015, the large employer mandate of the Affordable Care Act (ACA) requires that all full-time employees be offered minimum essential, affordable coverage. Penalties will be assessed for each month that a...more
On December 3, 2013, the U.S. Supreme Court unanimously reversed the U.S. Court of Appeals for the Fifth Circuit and held that (1) a federal district court in a partnership-level proceeding had jurisdiction to determine the...more
IRS Explains Federal Tax Consequences of Windsor Case Regarding Same-Sex Marriages -
In our last report (Vol. 8, No. 3, September 2013), we told you about the recent Windsor case, in which the Supreme Court held...more
Employers and plan sponsors must comply with numerous filing and notice deadlines for their retirement and health and welfare plans. Failure to comply with these deadlines can result in costly penalties and excise taxes. To...more
In This Issue:
- Labor and Employment and ERISA Class Actions After Wal-Mart and Comcast — Practice Points for Defendants (Part I – Commonality)*
- Agencies Release Guidance on HRAs, FSAs, and Employer Payment...more
Lawyers in every area run into clients who admit that they have not filed their tax returns. Among the many questions raised by this information are the following three, which come up nearly every time. This outline gives...more
- The IRS has signaled its intent to prosecute more small businesses for relatively low-value tax violations.
- In doing so, the IRS has increased its reliance on data-driven analyses of the...more
The Internal Revenue Service has issued proposed regulations on reporting requirements under the Affordable Care Act (ACA). The regulations, released on September 9, 2013, address two separate ACA reporting requirements: one...more
The U.S. Department of the Treasury and the Internal Revenue Service have published proposed rules establishing reporting requirements for employers and insurers under the Affordable Care Act (“ACA”), or Obamacare....more
On July 2, 2013, the Treasury Department made a surprise announcement that enforcement of the Employer Shared Responsibility Mandate, a provision of the Patient Protection and Affordable Care Act ("PPACA"), would be delayed...more
Health Care Reform: IRS Transitional Relief Delays Pay or Play Reporting and Penalties -
As we reported in an alert on July 3, the IRS has provided transitional relief to employers that delays pay or play reporting and...more
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