It is common for a US taxpayer to ask “what happens if you don’t file an FBAR or a Form 8938, Statement of Specified Foreign Assets with the IRS? Why do I have to worry about filing an FBAR in San Diego or anywhere in the US,...more
Could Artificial Intelligence (AI) increase the likelihood of an IRS audit in your future? How does the IRS use AI to identify US taxpayers who attempt to hide assets, under-report income or otherwise cheat the IRS? In...more
On December 4, the DOJ announced a deferred prosecution agreement and charges, in the Southern District of New York, a Swiss bank, requiring approximately $122.9 million in restitution for defrauding the U.S. government and...more
Designed for busy in-house counsel, compliance professionals, and anti-corruption lawyers, this newsletter summarizes some of the most important international anti-corruption law and enforcement developments from the past...more
UPDATE (3/20 PM): Developments Related to Flagstar Bank, SVBB, SVB Financial Group, Credit Suisse, and First Republic Bank- On March 19, 2023, the FDIC announced that the agency has entered into a purchase and...more
March 19, 2023- The Swiss Financial Market Supervisory Authority FINMA has approved the takeover of Credit Suisse by UBS. The Swiss National Bank (SNB) is also granting the merged bank further liquidity assistance that is...more
After a yearlong investigation, the US Senate Finance Committee probed into a FATCA Loophole and delivered an investigative report titled “The Shell Bank Loophole” that exposes a tax evasion scheme under a FATCA loophole...more
In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important international anti-corruption developments from the past month, with links to primary...more
We all know the French proverb; the more things change the more they stay the same. It has a place in the current controversy over the sudden collapse of Mt. Gox, Bitcoin’s leading dealer. Bitcoin is a virtual or...more
US Developments - US Senate Confirms SEC Commissioner Hester Peirce for Second Term - The U.S. Senate confirmed Securities and Exchange Commissioner Hester Peirce for a second term on Thursday alongside Caroline...more
On 31 March 2020, the Governments of France, Germany, and the United Kingdom (the so-called "E3") confirmed that the first transaction was completed through the Instrument in Support of Trade Exchanges ("INSTEX"),...more
Headlines that Matter for Companies and Executives in Regulated Industries - DOJ News - Government Intervenes Against Integrated Health Care System in False Claims Act Suit- The Department of Justice (the DOJ)...more
A Textbook Case of Alleged Money Laundering? On November 18, 2019, the U.S. Attorney for the Southern District of New York announced the arrest and unsealed the indictment of Bruce Bagley – a 73-year-old college professor...more
IRS Large Business and International (IRS LBI) currently has 59 Active Compliance Campaigns. The purpose of the IRS compliance campaign strategy is to redefine large business compliance work and build a supportive...more
For as long as there has been money, people have come up with creative ways of hiding it from others. As one could imagine, there have been more than a few instances of a divorcing spouse concocting an imaginative scheme to...more
Amazingly, April’s gone and it’s Jobs Report Friday again. Here’s what to look for in the numbers – Bloomberg and NYTimes and WSJ...more
On January 31, 2017, the IRS Large Business and International Division (LBI) announced a compliance campaign strategy to redefine large business compliance work and build a supportive infrastructure inside the LBI. ...more
• Since 2015, acquirers of Swiss non-listed bearer shares must report their name and address to the company within one month of the acquisition. The ultimate beneficial owner of an interest of 25 per cent or more has to be...more
Under Internal Revenue Code section 7609(f), the IRS may issue a “John Doe” administrative summons to discover the identities of unknown taxpayers. A “John Doe” summons can be a powerful enforcement tool because it allows the...more
In Ace Decade Holdings Ltd. v. UBS AG, No. 653316/2015, 2016 BL 413780 (N.Y. Sup. Ct. Dec. 7, 2016), Justice Eileen Bransten of the Commercial Division dismissed a $500 million fraud suit brought by an investment holding...more
The New York Court of Appeals recently gave a leg-up to plaintiffs seeking to hale foreign banks before New York state courts, clarifying that the use of a New York-based correspondent account could, under certain...more
The IRS currently offers the following five programs for noncompliant taxpayers: (i) the Offshore Voluntary Disclosure Program (OVDP), (ii) Streamlined Domestic Offshore Procedures, (iii) Streamlined Foreign Offshore...more
This issue of Skadden’s semiannual Cross-Border Investigations Update looks at Brexit’s impact on corporate crime and investigations, the U.S. DOJ’s increased use of forfeiture actions with international implications, current...more
Since 2008, the U.S. Government has largely focused its enforcement actions against Swiss banks that may have assisted U.S. taxpayers in evading federal taxes. In August 2013, the Department of Justice (“DOJ”) introduced the...more
Even with US markets shrugging off the Brexit [maybe?] by the end of last week, the effects of the split are FAR from over. One recent ripple: Standard Life Investments UK Real Estate mutual fund—which invests in high-end...more